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To: Laney, Michael N.

Subject: Emailing: cover letter HCL to Keith.doc, HCL ICR Test Report for Ste 

Genevieve.pdf, HCL ICR Test Report for Devils Slide.pdf, HCL ICR Test Report 

for Ada.pdf, Ste Genevieve HCl ICR Site Specific Test Protocol.pdf, Devils 

Slide HCl ICR Site Specific Test P

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HCL ICR Test Report for Devils Slide.pdf; HCL ICR Test Report for Ada.pdf; Ste 

Genevieve HCl ICR Site Specific Test Protocol.pdf; Devils Slide HCl ICR Site 

Specific Test Protocol.pdf; Ada HCl ICR Site Specific Test Protocol.pdf; HCL 

ICR Holcim.zip; HOLCIM _ Enclosure 6 M321 Spreadsheet.xls

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 Ste Genevieve HCl ICR Site Specific Test Protocol.pdf

 Devils Slide HCl ICR Site Specific Test Protocol.pdf

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Keith W. Barnett

USEPA/OAQPS/SPPD/MMG

Mail Code D243-02

Research Triangle Park, NC 27711

919-541-5605

barnett.keith@epa.gov

(See attached file: cover letter HCL to Keith.doc) (See attached file: HCL ICR 

Test Report for Ste Genevieve.pdf) (See attached file: HCL ICR Test Report for 

Devils Slide.pdf) (See attached file: HCL ICR Test Report for Ada.pdf) (See 

attached file: Ste Genevieve HCl ICR Site Specific Test

Protocol.pdf)

(See attached file: Devils Slide HCl ICR Site Specific Test

Protocol.pdf)

(See attached file: Ada HCl ICR Site Specific Test Protocol.pdf) (See attached 

file: HCL ICR Holcim.zip) (See attached file: HOLCIM _ Enclosure 6 M321 

Spreadsheet.xls)
DEECO Inc.

3404 Lake Woodard Road

Raleigh, NC 27604

(919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com

Site-Specific Test Plan

U.S. EPA Information Collection Request

for

Hydrogen Chloride Emissions

from

Portland Cement Manufacturing Facilities

Holcim (US) Inc. - Ada Oklahoma Plant

1100 West 18th Street

Ada, Oklahoma 74820

Submitted By:

DEECO, INC.

3404 Lake Woodard Road

Raleigh, NC 27603

February 20, 2010

Proposed Test Date: March 12, 2010
TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Test Program Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.0 SOURCE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

3.0 TEST PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3.1 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3.2 Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3.3 PROCESS PERFORMANCE INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

3.4 Test Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

4.0 SAMPLING LOCATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.1 Flue Gas Sampling Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

5.0 SAMPLING AND ANALYTICAL PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.1 Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.2 Sampling Point Determination - EPA Method 1 . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 . . . . . . . . . . . . . 10

5.4 Outlet Flue Gas Composition - EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . 10

5.5 Flue Gas Moisture Content - EPA Method 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10

5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.6.1 Test Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.6.2 Conditioning and Operational Test Periods . . . . . . . . . . . . . . . . . . . . . . . 13

5.6.3 Test Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

5.6.4 Test Procedures for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

5.6.4 Calibration Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.5 Test Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.6 Data Acquisition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

5.7 Test Procedures for EPA Method 321 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

6.0 QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

6.1 QC PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

6.1.1 Manual Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

6.1.2 Manual Sampling Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . 17

6.1.3 Manual Sampling Quality Control Procedures . . . . . . . . . . . . . . . . . . . . 22

7.0 REPORTING AND DATA REDUCTION REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . 25

Format . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

7.2 Data Reduction and Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26
TABLE OF CONTENTS (continued)

Section Page

8.0 PLANT ENTRY AND SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

8.1 Safety Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

8.2 Safety Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

8.3 Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE . . . . . . . . . . . . . . . . . . . . . 28

9.1 Test Site Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

9.2 Test Preparations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

9.3 Test Personnel Responsibilities and Detailed Schedule . . . . . . . . . . . . . . . . . . . 28

LIST OF TABLES

Table Page

TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS . . . . . . 5

TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE . . . . . . . . . . . . . 7

TABLE 6.1 SUMMARY QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLORIDE

EMISSION TEST RESULTS, HOLCIM (US) ADA, OKLAHOMA FACILITY;

MARCH 12, 2010 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

LIST OF FIGURES

Figure Page

Figure 1.1 Organization for Holcim (US) Inc. Ada, Oklahoma Facility HCl ICR Test Program

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Figure 4.1 Schematic of the Cement Kiln Stack sampling location . . . . . . . . . . . . . . . . . . . . . . . 9

Figure 6.1 Example field data sheet for EPA Methods 2 and 4 . . . . . . . . . . . . . . . . . . . . . . . . . . 18

Figure 6.2 Example field data sheet for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19
HCl ICR Site-Specific Test Protocol Page: 1

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

1.0 INTRODUCTION

1.1 Summary of Test Program

The U.S. Environmental Protection Agency (EPA), Office of Air Quality Planning and

Standards (OAQPS) has issued an Information Collection Request (ICR) to Holcim (US), Inc

(Holcim). Under the authority of Section 114 of the Clean Air Act (CAA). The EPA is requesting

information on hydrogen chloride (HCl) emissions from nonhazardous waste-burning kilns at

Portland cement manufacturing facilities. This request is in response to comments from Portland

cement industry members and its trade association to EPA’s proposal to amend the national emission

standards for hazardous air pollutants for Portland cement manufacturing (74 FR 21136 (May 6,

2009)).

Holcim has retained DEECO Inc. (DEECO) to conduct the required emissions testing.

Testing for HCl will be conducted in accordance with EPA Method 321 - Measurement of Gaseous

Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared (FTIR)

Spectroscopy. 

The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and

26A) may have positive biases due to chloride salts (such as ammonium chloride) that, when

collected in the sampling train, for chloride ions (Cl-

) that is indistinguishable from the Cl- ion

formed upon collection of HCl. In addition, a negative bias may also exist due to condensation

and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has

decided that the FTIR measurement by EPA Method 321 is the preferred technique for determining

the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement

manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/portland.pdf).

The Holcim facility located in Ada, Oklahoma in Pontotoc County (designated as the Ada

Oklahoma plant with the physical address of 1100 West 18th Street Ada, Oklahoma 74820) has been

one of the Portland cement manufacturing facilities selected as part of the ICR

HCl emission tests will be conducted at the main kiln stack. At this facility, the emissions

from two long, wet kilns are discharged through a single stack. The cement kilns are identified as

Cement Kiln #1 (461-KL1) and Kiln #2 (462-KL1) Common Stack

Testing is anticipated to be conducted March 12, 2010.

1.2 Test Program Organization

Figure 1.1 presents the test program organization, major lines of communication, and names

and phone numbers of responsible individuals.
HCl ICR Site-Specific Test Protocol Page: 2

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

EPA OAQPS, Sector Policies and

Programs Division

Peter Tsirigotis

Research Triangle Institute

Contract EP -D-06-118

EPA Sector Policies and

Programs Division

Keith Barnett

(919)541-5605

Barnett.Keitht@epa.gov

Holcim (US), Inc.

Corporate Contacts

Ruksana Mirza

or 

Hector Ybanez

Corporate Manager,

Environmental

(214) 524 - 2814

Hector.Ybanez@holcim.com

Holcim (US), Inc.

Environmental Contact

Timothy Schlosser

(734)529-4118

Timothy.Schlosser@holcim.com

EPA report data

contact

Ron Meyers 

(919) 541-5407

myers.ron@epa.gov

or 

Barrett Parker 

(919) 541-5635

parker.barrett@epa.gov

Holcim (US) Inc.

Ada Oklahoma Plant

Ms. Sharon Myers

(580) 421-8925

Sharon.Myers@holcim.com

EPA Test Method contact

Peter Westlin

(919) 541-1058

westlin.peter@epa.gov

or

Gary McAllister 

(919) 541-1062

mcalister.gary@epa.gov

DEECO Project Manager

Scott Steinsberger

(919)250-0285

deeco@deeco.com

DEECO Field Team

Figure 1.1 Organization for Holcim (US) Inc. Ada, Oklahoma Facility HCl ICR Test Program
HCl ICR Site-Specific Test Protocol Page: 3

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

2.0 SOURCE DESCRIPTION

2.1 Process Description

Holcim (US) operates a facility in Ada, Oklahoma for the manufacture of portland cement.

Facility operations include the operation of two raw mills for raw material processing, the production

of clinker in two wet kilns, the operation of a two clinker cooler systems, and the operation of two

finish mills. Kiln fuels include coal, coke, natural gas, TDF, and whole tires.

The airflow from each of the two kilns are directed to two electrostatic precipitators for

particulate removal before exhausting out a single, common stack.

2.2 Control Equipment Description

The airflow from each of the two kilns are directed to two electrostatic precipitators for

particulate removal before exhausting out a single, common stack.
HCl ICR Site-Specific Test Protocol Page: 4

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

3.0 TEST PROGRAM

3.1 Objectives

Testing for HCl will be conducted in accordance with EPA Method 321 - Measurement of

Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared

(FTIR) Spectroscopy. 

The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and

26A) may have positive biases due to chloride salts (such as ammonium chloride) that, when

collected in the sampling train, for chloride ions (Cl-

) that is indistinguishable from the Cl- ion

formed upon collection of HCl. In addition, a negative bias may also exist due to condensation

and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has

decided that the FTIR measurement by EPA Method 321 is the preferred technique for determining

the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement

manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/portland.pdf).

The specific objectives in order of priority are:

C Measure the emissions of HCl (EPA Method 321) from the Cement Kiln Stack during one

condition.

C Concurrent with the HCl measurements, measure the Cement Kiln Stack volumetric flow

rate (EPA Methods 1 and 2), the Cement Kiln Stack oxygen and carbon dioxide content

(EPA Method3A), and the Cement Kiln Stack moisture content.

Relevant process information will be collected by plant personnel in conjunction with the

testing program. The raw process data will be presented as collected in the appendices of the final

report.

3.2 Test Matrix

Table 3.1 presents the sampling and analytical matrix.
HCl ICR Site-Specific Test Protocol Page: 5

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS

Test

Parameter

Sampling

Method Sample Type

Sampling

Frequency Analytical Method

Measurement

Technique

Volumetric

Flow Rate

EPA Methods

1 and 2

Traverse points;

thermocouple

and Pitot tube

Concurrent

with each

Method 321

test

EPA Method 2

(40 CFR 60, App A)

Thermocouple

readout and 

manometer

Oxygen and 

Carbon

Dioxide

EPA Method

3A

Extractive

instrumental

sample

Concurrent

with each 

Method 321

test

EPA Method 3A

(40 CFR 60, App A)

Paramagnetic

for O2 and

NDIR for CO2

Moisture EPA Method

4

Traverse points;

Condensation

Concurrent

with each 

Method 321

test

EPA Method 4

(40 CFR 60, App A) Gravimetric

Hydrogen

Chloride

EPA Method

321

Extractive

instrumental

sample

Three 60-

minute

test runs per

condition

EPA Method 321

(40 CFR 63, App A)

Fourier

Transform

Infrared

(FTIR)

spectrometry 
HCl ICR Site-Specific Test Protocol Page: 6

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

3.3 PROCESS PERFORMANCE INFORMATION

Plant personnel in conjunction with the testing program will collect process information. The

raw process data will be presented as collected in the appendices of the final report.

3.4 Test Coordination

Ms. Sharon Myers, the Holcim facility contact, will serve as the test coordinator. She will be

responsible for:

1. Scheduling the start of all testing;

2. Principal contact with the agency officials concerning the tests;

3. Principal contact with DEECO concerning the tests;

4. Recording the process data during the testing; and 

5. Providing copies of any field test data to the agency.

A tentative test schedule is shown in table 3.2.
HCl ICR Site-Specific Test Protocol Page: 7

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE

Sampling Location Parameter(s)

Measured

Sampling

Method

Number of Runs

and Duration

Length of

Day(s)

Day 1 - March 11, 2010 Arrive on-site and set up test equipment 8 hours

Day 2 - March 12, 2010

Kiln Stack Flue Gas Flowrate EPA Methods 1, 2, 4 Three 60-minute

runs per condition

10 hours

O2/CO2 EPA Method 3A

HCl EPA Method 321

Day 3 - March 13, 2010 Contingency Day
HCl ICR Site-Specific Test Protocol Page: 8

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

4.0 SAMPLING LOCATIONS

4.1 Flue Gas Sampling Location

The main stack is a vertically oriented, round stack with an inside diameter of 186 inches. The

test location is approximately 130 feet above ground level. Four test ports, each four inches in

diameter, are located 90E apart around the stack circumference. The test ports are located about 6.4

equivalent stack diameters downstream and 7.74 equivalent stack diameters upstream of the nearest

flow disturbances. The sampling location meets the minimum specifications for selection of a

measurement site as outlined in EPA Method 1.

A schematic of the Cement Kiln Stack sampling location is shown in Figure 4.1
HCl ICR Site-Specific Test Protocol Page: 9

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

Figure 4.1 Schematic of the Cement Kiln Stack sampling location.
HCl ICR Site-Specific Test Protocol Page: 10

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

5.0 SAMPLING AND ANALYTICAL PROCEDURES

5.1 Test Methods

This section contains a brief description of the sampling and analytical procedures for each

method that will be employed during the test program. All equipment, procedures, and quality

assurance measures necessary for completion of the test program will meet or exceed the

specifications of the appropriate methods. Any deviations from the methods to ensure quality

representativeness of the results are also discussed.

5.2 Sampling Point Determination - EPA Method 1

A minimum eight (8) point velocity traverse will be made in each of two perpendicular

directions (4 points in each of the 4 sampling ports). Each traverse will be made at each sampling

location using a type-S pitot tube in accordance with EPA Methods 2 procedures

5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2

The flue gas velocity and volumetric flow rate will be determined according to the procedures

outlined in EPA Method 2. Velocity measurements will be made using type S pitot tubes conforming

to the calibration specifications outlined in EPA Method 2, Section 10.1. Each Type-S pitot tube,

calibrated according to these standards, will have an assigned coefficient. Differential pressures will

be measured with Magnehelic gauges of appropriate range or with fluid manometers. Effluent gas

temperatures will be measured with chromel-alumel thermocouples equipped with digital readouts.

5.4 Outlet Flue Gas Composition - EPA Method 3A

Outlet flue gas analysis for oxygen (O2

) and carbon dioxide (CO2) concentrations, and the

calculation of percent excess air and flue gas dry molecular weight will be performed in accordance

with EPA Method 3A. Refer to Section 5.6 for more information

5.5 Flue Gas Moisture Content - EPA Method 4

The flue gas moisture content will be determined in conjunction with each sampling run and

according to the sampling and analytical procedures outlined in EPA Method 4. The impingers will

be connected in series, and contained in an ice bath in order to assure condensation of the moisture

in the flue gas stream. Any moisture that is not condensed in the impingers is captured in the silica

gel, therefore all moisture can be weighed and entered into moisture content calculations.
HCl ICR Site-Specific Test Protocol Page: 11

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321

A CEM system will be used to determine oxygen and carbon dioxide concentrations and

hydrogen chloride concentrations on the Main Kiln/Raw Mill stack. The procedures used in meeting

these requirements are detailed below.

5.6.1 Test Equipment Description

The instrumentation and all sampling and analytical procedures that will be used by DEECO

for the HCl ICR testing will conform with the requirements of EPA Test Methods 3A and 321 using

FTIR.

For HCl, the extractive system requires that the effluent gas sample be filtered and maintained

at a minimum of 356°F (180°C) prior to being delivered to the FTIR sample cell. The FTIR sample

cell will also be maintained at 356°F. The gas sample will be drawn through the extractive system

and the FTIR cell using a heated sample pump. The extractive system will be equipped with a glass

lined probe also heated to a minimum of 356°F. The probe will be of sufficient length to reach a

minimum of three traverse points at 17, 50, and 83 percent of the duct diameter or 0.4, 1.2, and 2.0

meters from the stack or duct wall, which ever is less. All components of the sampling system which

contact the sample will be either of glass, stainless steel, or Teflon

The extracted gas sample exiting the heated sample pump will be conditioned to remove

moisture with an ice water-cooled condenser. A gas distribution manifold will be used to deliver a

representative sample of flue gas to oxygen and carbon dioxide analyzers.

Fourier Transform Infrared (FTIR) spectroscopy for Hydrogen Chloride - FTIR spectroscopy

measures vapor phase organic or inorganic compounds which absorb energy in the mid-infrared

spectral region, about 400 to 4000 cm-1 (25 to 2.5 μm). Continuous measurement is made by

matching sample absorbance bands with bands in reference spectra, and comparing sample band

intensities with reference band intensities.

The principle limitation to FTIR spectroscopy are the presence of interfering compounds that

also absorb energy in the mid-infrared spectral region. In a cement kiln stack gas matrix, water vapor

(H2O) and carbon dioxide (CO2

) are the primary interferents that must be incorporated into the

identification and quantitation method.

By choosing the proper analytical region(s) for the HCl spectra, the effect of the interfering

compounds can be minimized. The analytical regions will be selected based on examination of the

actual stack gas matrix. (It should be noted that the analytical region provided as an example in EPA

Method 321 (2679-2840 cm-1) does not correspond with the entire analytical region for HCl (2600-

3100 cm-1). The example cited in Method 321 appears to have been copied from the formaldehyde

analytical region used as an example in Method 318.)

The FTIR software performs the computation for a single compound by subtracting all the

other compounds (interferants and target) from the absorbance spectra and quantifies the single

compound based on the remain absorbance. The FTIR software provides a Standard Error

Calculation (SEC) value that is an indication of how well the identification and quantitation has been

performed. A high SEC indicates that other interferants have not been accounted for in the analysis
HCl ICR Site-Specific Test Protocol Page: 12

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

method, and a low SEC is indicative of greater confidence mesurement. Typically, if the reported

SEC is greater than half the reported concentration then the results is suspect. 

A MIDAC I-Series FTIR will be used to determine HCl concentrations according to EPA

Method 321. Infrared absorption spectroscopy is performed by directing an infrared beam through

a sample to a detector. The frequency-dependent infrared absorbance of the sample is measured by

comparing this detector signal (single beam spectrum) to a signal obtained without a sample in the

beam path (background). Most molecules absorb infrared radiation and the absorbance occurs in a

characteristic and reproducible pattern. The infrared spectrum measures fundamental molecular

properties and a compound can be identified from its infrared spectrum alone. Within constraints,

there is a linear relationship between infrared absorption and compound concentration. If this

frequency dependent relationship (absorptivity) is known (measured), it can be used to determine

compound concentration in a sample mixture.

Absorptivity is measured by preparing, in the laboratory, standard samples of compounds at

known concentrations and measuring the FTIR "reference spectra" of these standard samples. These

"reference spectra" are then used in sample analysis: (1) compounds are detected by matching sample

absorbance bands with bands in reference spectra, and (2) concentrations are measured by comparing

sample band intensities with reference band intensities.

Reference spectra for hydrogen chloride and sulfur hexafluoride will be generated from

commercially-available calibration gas cylinders. The EPA reference spectra available from the

EPA’s Emission Measurement Center are not representative of the concentrations (at 189.5 ppmmeters and 497.3 ppm-meters) being measured. HCl reference spectra at 2 ppm and 5 ppm (16.3

ppm-meters and 40.8 ppm-meters) will be used. Secondly, higher resolution spectra, compared to

the EPA reference spectra, will be necessary due to the low HCl concentrations that are expected and

the high moisture levels (up to 35%) that will be encountered. Thirdly, errors have been reported for

certain EPA reference spectra, so the entire EPA reference spectra data base should be suspect.

CAI Model 200 O2

/CO2 Analyzer - The CAI Model 200 O2/CO2 analyzer houses two measurement

principles in one instrument. The oxygen concentrations are measured using the parapneumatic

technique. Because of its sp3 electron orbital distribution, an oxygen molecule has an unpaired

electron and hence displays a magnetic orientation. Since other elements that display this magnetic

phenomenon are not common gasses at normal temperatures, the parapneumatic measurement

technique is virtually specific for oxygen. The sample gas flows through a detection cell located in

a very strong magnetic field. The magnetic nature of the oxygen causes the oxygen to move to one

side of the detection cell, inducing a pressure differential proportional to the oxygen concentration

in the detector cell. The analyzer measures this pressure differential, converts the pressure differential

to an electrical signal, and sends the results as output.

The carbon dioxide concentrations are measured using a single-beam photometric system with

a micro flow sensor detector. The micro flow detector is a sealed unit filled with carbon dioxide.The

instrument consists of an infrared light source, a chopper, a measuring cell and a micro flow detector

filled with carbon dioxide. The infrared light emitted backward is reflected by a reflecting surface

and is added to the infrared light emitted forward. Arranged between the infrared light source and

the measuring cell is a chopper blade which rotates to modulate the infrared light beam at regular

frequency. The modulated infrared light beam thus formed passes through the measuring cell filled

with a sample gas where the light energy is partially absorbed or attenuated before it reaches the front
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chamber of the detector. Both the front and rear chambers of the detector are filled with the gas

component to be measured. The infrared light energy is partially absorbed in the front chamber and

residual light is absorbed in the rear chamber, thereby increasing the pressure in both chambers.

Since the detector is designed to produce a pressure difference between the front and rear chambers,

a slight gas flow is produced through a path connecting these chambers with each other. This slight

flow is converted into an AC electrical signal by a micro flow sensor.

5.6.2 Conditioning and Operational Test Periods 

The conditioning and operational test periods will be completed and sampling commenced

once all monitors are found to be acceptable.

5.6.3 Test Requirements

DEECO's extractive measurement system and all sampling and analytical procedures for

testing will conform to the requirements of EPA Methods 2, 3A, and 4 of 40 CFR 60 and EPA

Method 321 of 40 CFR 63.

The extractive monitors require that the effluent gas sample be conditioned to eliminate any

possible interference (water vapor and particulate matter) before being transported and injected into

each analyzer. All components of the sampling system that contact the sample are Type 316 stainless

steel, glass, or Teflon.

A heated probe with an in-stack particulate filter, heated sample lines, moisture removal trap,

a sample pump, and distribution manifold board are used to deliver a representative sample of flue

gas to the analyzers. The sampling probes are constructed of 316 stainless steel and are heated

electrically to maintain the sample temperature above the dew point. 

The sample acquisition and conditioning system also includes two injection ports: (1)

immediately upstream of the analyzers for analyzer linearity checks, and (2) at the outlet of the probe

for the sampling system bias and calibration drift checks. This arrangement provides both ease in

checking the analyzer performance and a means of evaluating the entire monitoring system.

5.6.4 Test Procedures for EPA Method 3A

All analyzers will be subjected to an interference check similar to the procedures in Section

5.4 of EPA Method 20. During calibration, all analyzers’ response will be noted while introducing

each calibration gas. If the sum of the interference responses of the test gases for any of the analyzers

is greater than 2 percent of the applicable span value, corrective measures on the analyzer will be

taken, up to and including replacement of the analyzer.

Calibration procedures will be performed in accordance with EPA methodology. Analyzers

will be calibrated before and after each test and a calibration check will be done between each test

run.
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The pretest calibrations will consist of the following steps:

• Internal (direct) calibration of each analyzer to adjust calibration and check linearity.

• External (through the entire sampling system) calibration to check the system bias on

zero and span gases.

The post test calibration will consist of an external system bias calibration check.

5.6.4.1 Internal Calibration - Each analyzer will be calibrated using a certified zero and span (mid

or high range as necessary) gas. Zero and span gases will be directed to each analyzer through the

appropriate plumbing, the calibration gas flow rates will be adjusted to the correct flow rate and the

analyzer will be adjusted with the appropriate span pot. After the analyzer is properly adjusted the

linearity will be checked using a mid range calibration gas. The maximum allowable limit for

linearity is 2% of the analyzer range. All analyzers will be shown to be linear within these limits

before proceeding.

5.6.3.2 External Calibration - The external calibration bias check will be performed by placing the

CEM system in the sampling mode and injecting a zero and span gas into the sample line at the probe

exit. This check will show if there was any sampling system related bias, and also served as a check

of the integrity of the sample line.

5.6.4 Calibration Gases

DEECO will use EPA Protocol #1 gases for calibration as required by the various reference

methods used in this test program. Calibration gases will be selected from previous experience with

similar sources and/or from information obtained from the facility engineer prior to sampling. Audit

gases, if available from federal or state agencies, will be analyzed.

5.6.5 Test Procedures

At the completion of the pretest calibration routine, the CEM system will be ready for

operation. No further adjustments of sample flow rates, analyzer zero or span adjustments, or other

critical CEM operating parameters will be made until testing and post test calibration are complete.

The CEMs will be allowed to at least 21 minutes to complete each test run. At the completion for

each run, calibration gases nearest to the measured emission levels will be used to check each

instrument.

During each sampling run, a sampling traverse will be performed to ensure the absence of

stratification. Traverse points will be selected that assure acquisition of representative samples over

the stack or duct cross section. A minimum requirement is the establishment of a "measurement line"

that passes through the centroidal area and in the direction of any expected stratification. If this line

interferes with the CEM measurements, the line will be displaced up to 30 cm (12 in.) (or 5 percent

of the equivalent diameter of the cross section, whichever is less) from the centroidal area. Per

Section 6.5.6.3(a) of 40 CFR 75, three traverse points will be located 16.7, 50.0, and 83.3 percent of

the measurement line, and measured equally during each run. Alternatively, per Section 6.5.6.3(b)

of 40 CFR 75, a single sampling point may be used if the concentration of each compound at each

individual traverse point differs by no more than ±5.0 percent from the arithmetic average

concentration for all traverse points.
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Concurrent measurements of flow following EPA Methods 1, 2, 3A, and 4 (Sections 5.1

through 5.5) will be used to determine flue gas emission rates of all target compounds.

5.6.6 Data Acquisition

Data will be recorded on two separate devices. A hard copy will be obtained using a Molytek

2702 strip chart recorder. Data will also be recorded to the hard disk of an IBM compatible computer

utilizing the serial output of the Molytek recorder in conjunction with custom software. Data for each

of the analyzers will be sampled each second with a one-minute average being written to disk. Data

will be further averaged over the test period and corrected for calibration error and drift using a

spreadsheet program.

5.7 Test Procedures for EPA Method 321

The FTIR optics and sample cell will be purged with nitrogen overnight. A backgroung

spectra will be collected will purging nitrogen thorough the cell at a flow rate low enough that the cell

pressure is not elevated above ambient pressure. Next an ethylene Calibration Transfer Standard

(CTS) will be passed thorough the cell, again at a flow rate low enough that the cell pressure is not

elevated above ambient pressure, and spectra will be collected of the CTS gas. By setting the cell

pressure in the software to reflect the ambient pressure, the path length can be verified and adjusted

as needed. 

As part of the HCl analyte spiking procedure, the calibration gas mixture containing HCl and

sulfur hexafluoride (SF6

) will then be passed directly to the cell, again at a flow rate low enough that

the cell pressure is not elevated above ambient pressure. This will establish the undiluted

concentration of the HCl/SF6 mixture to be used in the analyte spike recovery calculations.

Next the heated sample line will be connected directly to the sample cell, and stack gas will

be drawn through the cell prior to the pretest analyte spiking.

The first step in the analyte spiking will be to send the CTS to the sample probe and back

through the sampling system. Spectra of the CTS gas will be collected and the cell pressure setting

in the software will be adjusted as needed to provide the correct CTS reading.

After the CTS check is completed, stack gas will again be sampled to provide a pre-spike

native concentration of HCl.

Next the HCl/SF6

 gas mixture will be directed to the sample probe at a flow rate

approximately 10% of the total sample rate such that the stack gas provides a nominal 10-fold dilution

of the analyte spike. Once a satisfactory spike recovery of 70%-130% has been is achieved, the

HCl/SF6 gas mixture will be turned off. The HCl/SF6 spike will be purged from the system and

additional spectra will be collected from the stack gas to determine the post spike concentration of

the native HCl.
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It should be noted that there are errors in the Method 321 equation used to calculate the

analyte spike recovery. Consequently the following correct equation will be used;

%R

C C

DF

C

DF

t n

s

=

− −













×

×

1

1

1

100

%R = Spike Recovery

Ct = Concentration of the total HCl (spike plus native), ppm,

Cn = Average concentration of the native HCl (pre and post spike), ppm,

Cs = Concentration of the HCl spike, ppm; and

DF = Ratio of the undiluted SF6

 tracer gas concentration to the diluted SF6 measured during

analyte spiking 
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6.0 QA/QC ACTIVITIES

6.1 QC PROCEDURES

Example data sheets for EPA Methods 2 and 4 and EPA Method 3A are provided in Figures

6.1 and 6.2.

Specific QA/QC parameters for each method is provided in Table 6.1 and described in detail

below.

6.1.1 Manual Sampling Equipment

Each item of field test equipment will be assigned a unique, permanent identification number.

An effective preventative maintenance program is necessary to ensure data quality. Each item of

equipment returning from the field will be inspected before it is returned to storage. During the

course of these inspections, items are cleaned, repaired, reconditioned, and recalibrated where

necessary.

Each item of equipment transported to the field for this test program will be inspected again

before being packed to detect equipment problems which may originate during periods of storage.

This minimizes lost time on the job site due to equipment failure.

Occasional equipment failure in the field is unavoidable despite the most rigorous inspection

and maintenance procedures. For this reason, replacement equipment for all critical sampling train

components will be transported to the job site.

6.1.2 Manual Sampling Equipment Calibration

New items for which calibration is required will be calibrated before initial field use.

Equipment whose calibration status may change with use or time will be inspected in the field before

testing begins and again upon return from each field use. When an item of equipment is found to be

out of calibration, it will be repaired and recalibrated or retired from service. All equipment will be

periodically recalibrated in full, regardless of the outcome of these regular inspections.

Calibrations will be conducted in a manner, and at a frequency, which meets or exceeds U.S.

EPA specifications. The calibration procedures outlined in the EPA Methods will be followed.

When these methods are inapplicable, methods such as those prescribed by the American Society for

Testing Materials (ASTM) will be used.

Data obtained during calibrations will be recorded on standardized forms, which will be

checked for completeness and accuracy by the quality assurance manager. Data reduction and

subsequent calculations will be performed using computer facilities. Calculations will be checked

at least twice for accuracy. Copies of calibration forms will be included in the final test report.

Emissions sampling equipment requiring calibration includes pitot tubes, pressure gauges,

thermometers, dry gas meters and barometers. The following sections elaborate on the calibration

procedures to be followed for these items of equipment.
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Flow rate and Moisture Measurement Data Sheet

Plant and City Date Sampling Location Sample Type Run No.

Operator

Barometric

Pressure

(Pb)

(In. Hg)

Static

Press

(in. H2O)

Ambient

Temp

(deg. F)

Stack

ID

(In.)

Pitot

Cp

DGM

Box No.

DGM

delta H@

DGM Cal

Factor

(gamma)

Probe

 ID

No.

EPA Method 3/3A Data EPA Method 4 Impinger Weights

Oxygen, % Impinger 1 2 3 Sil.Gel

Carbon Dioxide, % Final Wt., g Color

Nitrogen, % Initial Wt., g % Spent

Net Wt., g

Total Collected , g

EPA Method 2 Data EPA Method 4 Sampling Data

Run Time

(24 hr)

Port/Point

ID 

Pitot

delta P

(in. H2O)

Stack

Temp

(deg. F)

Run Time

(24 hr)

DGM

Reading

(cu.ft.)

DGM

delta H 

(in. H2O)

DGM

Temps

(deg. F)

Exit

Temp

(deg. F)

Sample

Train Vac.

(In. Hg)

Initial Leak Rate cfm @ “Hg

Final Leak Rate cfm @ “Hg

Pitot Leak Check

Figure 6.1 Example field data sheet for EPA Methods 2 and 4
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Plant and City Test Location Date Operator

Cylinder

ID

Gas

Type Value

Internal

Response

Cal

Error

Run No. Run Time

Pre Run

Bias

Percent

Bias

Post Run

Bias

Percent

Bias

Percent

Drift

O2 Zero Zero N2

CC5134 O2 Mid 11.9%

CC117302 O2 Span 21.9%

CO2 Zero Zero N2

CC5134 CO2 Mid 20.4%

CC117302 CO2 Span 35.5%

Figure 6.2 Example field data sheet for EPA Method 3A
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TABLE 6.1 SUMMARY QA/QC ACTIVITIES

Test Equipment QC Parameter Target

Volumetric Flow Rate Measurement

Pitot Tube Pitot Geometry Within Specifications

Thermocouple <1.5% absolute

Pitot Leak Check stable 15 sec at $4 in. WC

Dry Gas Meters for Particulate Sampling

Dry Gas Meters Initial Calibration 0.95 # γ # 1.05 

individual γ RSD # 2%

Post Test Calibration Check Post test γ # 5%

Post Test Leak Checks <2% of sample rate 

EPA Method 3A

Initial Calibration Zero Gas <2% of Span Gas

Mid Range Gas <2% of Span Gas

Span Gas <2% of Span Gas

Bias Checks Zero Gas <5% of Span Gas

Mid Range Gas <5% of Span Gas

Drift Zero Gas <5% of Span Gas

Mid Range Gas <5% of Span Gas

Method 321 for Hydrogen Chloride

Pre/Post CTS Calibration Precision Pre and post quantification #5% RSD

Direct HCl Calibration Precision Duplicate measurement #5% RSD

HCl Analyte Spike System Validation Spike Recovery 70% - 130%
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A: Pitot Tubes. All Type S pitot tubes used, whether separate or attached to a sampling

probe, will be constructed in-house or by a third-party vendor. Each new pitot will be

calibrated in accordance with Section 10.1 of EPA Method 2. Each Type-S pitot tube,

calibrated according to these standards, will have an assigned coefficient. This

coefficient should not change as long as the pitot tube is not damaged.

 

 Each pitot tube will be inspected visually upon return from the field. If a cursory

inspection indicates damage or raises doubt that the pitot remains in accordance with

the EPA geometry standards, the pitot tube will be refurbished as needed and

recalibrated.

B: Differential Pressure Gauge. All meter consoles used are equipped with 10-inch

water column (W.C.) inclined-vertical manometers. Fluid manometers do not require

calibration other than leak checks. Manometers will be leak checked in the field prior

to each test series, and again upon return from the field.

C: Impinger Thermometer. Prior to the start of testing, the thermocouple used to

monitor the temperature of the gas leaving the last impinger will be compared with a

mercury-in-glass thermometer which meets ASTM E-1 No. 63F specifications. The

impinger thermocouple is replaced if it does not agree within 2EF of the reference

thermometer. After each field use, the thermocouple will be checked per EPA Alt-011

procedures.

D: Dry Gas Meter Thermometer. The thermocouple used to measure the temperature

of the metered gas sample will be checked prior to initial field use against an ASTM

mercury-in-glass thermometer. The dry gas meter thermocouple is acceptable if the

values agree within ±2EF. Thermocouples not meeting this requirement will be

replaced. After each field use, the thermocouple will be checked per EPA Alt-0011

procedures.

E: Flue Gas Temperature Sensor. All thermocouples employed for the measurement

of flue gas temperature are calibrated upon receipt. Initial calibrations will be

performed at three points (ice bath, boiling water, and hot oil). An ASTM mercury-inglass thermometer will be used as a reference. The thermocouple is acceptable if the

agreement is within 1.5 percent (absolute) at each of the three calibration points.

After each field use, the thermocouple will be checked per EPA Alt-011 procedures.

Before each field use, the reading from the flue gas thermocouple-potentiometer

combination will be compared with an ASTM mercury-in-glass reference

thermometer at ambient conditions. If the two agree within ±1.5 percent (absolute),

the thermocouple and potentiometer are considered to be in proper working order.

F: Dry Gas Meter and Orifice. Two procedures will be used to calibrate the dry gas

meter and orifice simultaneously. The full calibration will be a complete laboratory

procedure used to obtain the calibration factor of the dry gas meter. Full calibrations

will be performed over a wide range of orifice settings. A simpler procedure, the posttest calibration, will be designed to check whether the calibration factor has changed.
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A dry gas meter that is calibrated annually against a spirometer or a set of calibrated

critical orifices will be used as a transfer standard. During the annual calibration,

triplicate calibration runs will be performed at seven flow rates ranging from 0.25 to

1.40 cfm.

G: Dry Gas Meter. Each metering system receives a full calibration at the time of

purchase and a post-test calibration after each field use. If the calibration factor, γ,

deviates by less than five percent from the initial value, the test data are acceptable.

If γ deviates by more than 5 percent, the meter is recalibrated and the meter coefficient

(initial or recalibrated) that yields the lowest sample volume for the test runs is used.

EPA Method 5 requires another full calibration anytime the post-test calibration check

indicates that γ changed by more than 5 percent. Standard practice is to adjust and

recalibrate the dry gas meter anytime γ is found to be outside the range of 0.96 to 1.04.

Post-test calibrations will be performed after each field test series per EPA Alt-009

procedures.

H: Orifice. An orifice calibration factor will be calculated for each flow setting during

a full calibration. If the range of values does not vary by more than 0.15 in H2O over

the range of 0.5 to 4.0 in H2O, the arithmetic average of the values obtained during the

calibration is used.

I: Barometer. Each field barometer will be adjusted before each test series to agree

within ±0.1 inches of a reference mercury-column barometer. The reference

barometer will be checked against the station pressure value (corrected for elevation

difference) reported by the National Weather Service.

6.1.3 Manual Sampling Quality Control Procedures

The following pretest QC checks will be conducted:

• All sampling equipment will be thoroughly checked to ensure clean and operable

components.

• Equipment will be inspected for possible damage from shipment.

• The oil manometer or Magnehelic gauge used to measure pressure across the Type S

pitot tube will be leveled and zeroed.

• The number and location of the sampling traverse points will be checked before taking

measurements.

• The temperature measurement system will be visually checked for damage and

operability by measuring the ambient temperature prior to each run.

In addition to the general QC procedures listed above, QC procedures specific to each

sampling method will also be incorporated into the sampling scheme. These methods and specific

procedures are discussed below.
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A: Sampling Train QC checks. The following QC procedures will be emphasized:

Prior to Start of Tests

• Keep all cleaned glassware and sample train components sealed until train

assembly.

• Assemble the sampling trains in an environment free from contamination. 

• Visually inspect each sampling train for proper assembly.

• Perform pretest calculations to determine the proper sampling nozzle size.

Prior to Each Test Run

• Visually inspect the sampling nozzle.

• Visually inspect the Type S pitot tube.

• Leak check each leg of the Type S pitot tube.

• Leak check the entire sampling train.

During Each Test Run

• Readings of temperature and differential pressure will be taken at each

traverse point.

• All sampling data and calculations will be recorded on preformatted data

sheets.

• All sampling data forms will be reviewed for completeness and accuracy.

• Any unusual occurrences will be noted during each run on the appropriate data

form.

• The project supervisor will review sampling data sheets daily during testing.

• Properly maintain the roll and pitch axis of the Type S pitot tube and the

sampling nozzle.

• Leak check the train before and after any move from one sampling port to

another during a run (at DEECO’s option) or if a filter change takes place.

• Maintain the probe, filter, and impingers at the proper temperatures.

• Maintain ice in the ice bath at all times.

• Make proper readings of the dry gas meter, delta P and delta H, temperature,

and pump vacuum during sampling at each traverse point.

• Maintain isokinetic sampling within ± 10% of 100%.

After Each Test Run

• Visually inspect the sampling nozzle.

• Visually inspect the Type S pitot tube.

• Leak check each leg of the Type S pitot tube.

• Leak check the entire sampling train.

B: QC for Volumetric air flow rate determinations
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Flue Gas Velocity. Data required to determine the flue gas velocity will be collected

using the methodology specified in EPA Method 2. Quality control procedures are

as follows.

• Visually inspect the Type S pitot tube before and after sampling.

• Leak check both legs of the pitot tube before and after sampling.

• Check the number and location of the sampling traverse points before taking

measurements.

Flue Gas Molecular Weight. Samples to be used for determination of flue gas

molecular weight will be collected using the continuous sampling technique specified

in EPA Method 3A. Quality control will focus on the following procedures:

• The sample acquisition system will be leak checked before operation.

• A constant sampling rate will be used in withdrawing a sample.

• The sampling port will be properly sealed to prevent air in-leakage.

Moisture Content. The moisture content of the gas stream will be determined using

the technique specified in EPA Method 4. The following QC checks will be

performed:

• The sampling train will be leak checked before and after each run.

• Ice will be maintained in the ice bath throughout each run.
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7.0 REPORTING AND DATA REDUCTION REQUIREMENTS

7.1 Report Format

TABLE OF CONTENTS

1.0 Introduction 

1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

1.2 Key Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.0 Source and Sampling Location Descriptions

2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.3 Flue Gas and Process Sampling Locations . . . . . . . . . . . . . . . . . . . . . . . . X

3.0 Summary and Discussion of Results

3.1 Objectives and Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

3.2 Field Test Changes and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

3.3 Summary of Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

4.0 Sampling and Analytical Procedures 

4.1 Emission Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

4.2 Process Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

5.0 QA/QC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

APPENDICES

A - Results and Calculations

B - Raw Field Data

C - CEM Results

D - FTIR Results

E - Equipment Calibration Data Sheets and Calibration Certificates of Analysis

F - List of Participants
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7.2 Data Reduction and Summary

An example data summary table is shown as Table 7.1.

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLORIDE

EMISSION TEST RESULTS, HOLCIM (US) ADA, OKLAHOMA FACILITY;

MARCH 12, 2010 

Test Parameter Run X Run X Run X Average

Time xx:xx-xx:xx xx:xx-xx:xx xx:xx-xx:xx ----

Stack Gas Temperature (EF) xxx xxx xxx xxx 

Stack Gas Moisture x.x% x.x% x.x% x.x%

Volumetric Flowrate

 actual cfm

 dry standard cfm

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

Oxygen Content x.x% x.x% x.x% x.x%

Hydrogen Chloride Emissions

 Concentration, ppmby volume, wet basis

 Concentration, ppmby volume, dry basis

 Concentration, ppm at 7% oxygen

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx
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8.0 PLANT ENTRY AND SAFETY

8.1 Safety Responsibilities

The DEECO Safety Officer (Dr. Scott Steinsberger) is responsible for ensuring compliance

with plant entry, health, and safety requirements.

The Holcim Devils Slide Plant Contact (Sharon Myers) has the authority to impose or waive

facility restrictions.

The DEECO Test Director (Dr. Scott Steinsberger) has authority to negotiate with facility

person any deviations from the facility restrictions.

8.2 Safety Program

The DEECO Health and Safety Program is attched as Appendix A.

8.3 Safety Requirements

All test personnel will adhere to the following standard safety and precautionary measures

as follows:

C Confine selves to test area only.

C Wear hard hats at all times on-site, except inside sample recovery trailers

and mobile CEM laboratory.

C Wear protective shoes or boots in test area.

C Wear protective glasses or goggles at the test sites, and other areas as

designated.

C Have readily available first aid equipment and fire extinguishers.

Before or on the first day on-site, the Test Director will fill out the Holcim

Contractor Job Safety Plan and the Pre-Shift Hazard Assessment form and provide

copies to be posted at each test site.
HCl ICR Site-Specific Test Protocol Page: 28

Holcim (US) Inc. Revision No: 0

Ada, Oklahoma Date: February 20, 2010

9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE 

9.1 Test Site Organization

The key tasks and task leaders are:

C Management: William G. DeWeeS

C Test Preparation/Site Restoration: Scott C. Steinsberger

C Modifications to Facility/Services: Sharon Myers

C Sampling Site Accessibility: Sharon Myers

C Sample Recovery:Marc Hamilton

C Daily Sampling Schedule: Scott C. Steinsberger

9.2 Test Preparations

No special sampling and analytical equipment is needed. No modifications to the facility are

needed. Suitable safe access to the sampling location currently exists. Holcim will provide the

necessary electrical power. Sample recovery of the Method 4 trains will be conducted in a mobile

recovery laboratory already on-site.

9.3 Test Personnel Responsibilities and Detailed Schedule

DEECO personnel will arrive at the plant about 1.5 hours before the start of the first test run

on each of the two days scheduled for sampling. Pre-test activities on these days will include:

C Meet with the plant contact to review the daily test objectives.

C Prepare and set-up (including leak checks) the manual method trains at all test locations.

C Calibrate instrumental analyzers and verify that the data acquisition systems are

functioning properly.

C Verify communication links between team members/leaders/plant personnel.
Appendix A

DEECO Health and Safety Plan
DEECO Inc.

3404 Lake Woodard Road

Raleigh, NC 27604

(919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com

DEECO

HEALTH AND SAFETY PLAN

January 2010
DEECO

Health and Safety Plan

Section Page

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Employee Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1.3 Pre-Work Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1.4 Employee Safety Education, Training, and Evaluation . . . . . . . . . . . . . . . . . . . . . 4

2.0 General Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.1 First Aid for Accidents and Injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.2 Audit/Inspection Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2.3 Bloodborne Pathogens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.4 Aerial Devices (Man Lifts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.6 Documented Safety Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.8 Electrical - GFCI or Grounding Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

2.9 Equipment Inspection/Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.10 Excavation/Trenching/Shoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.11 Floor/Wall Openings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.12 Hearing Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.13 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.14 Manual Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.15 Mechanical Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.16 Mechanical and Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.17 New Employee Orientation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.18 Power and Hand Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.19 Process Safety Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.20 Scaffolding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.21 Stairways and Ladders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

2.22 Travel Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.23 Thermal Stress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.24 Welding and Cutting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

2.26 Lockout/Tagout (LOTO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

2.27 Fall Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen

Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

2.29 Emergency Response/Evacuation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

2.30 Compressed Air Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

2.31 Concrete Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

2.32 Powder-Actuated Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
Section Page

3.0 Chemical Safety Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

3.1 General Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

3.2 Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.3 Bases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.4 Compressed Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

3.5 Cryogenic Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

3.6 Flammable Liquids and Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

3.7 Organic Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

3.8 Oxidizing Agents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

3.9 Asbestos Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

3.10 Benzene Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

3.11 Hydrogen Sulfide Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

3.12 Lead Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

4.0 Hazard Communication Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

4.1 Material Safety Data Sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

4.2 Chemical Labelling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

4.3 Employee Exposure Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

4.4 Employee Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

4.5 Employee Access to Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

5.0 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

5.1 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

5.2 Gloves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

5.3 Protective Eyewear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

5.4 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

5.5 OSHA Levels of Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

5.5 Training for the Use Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . 70
DEECO Health and Safety Plan Page 1 January 2010

1.0 Introduction

DEECO, Inc. (DEECO) is committed to the health and safety of its employees. In order to ensure

that all tasks are performed safely, this Health and Safety Plan (HSP) has been prepared. The

procedures detailed in this HSP outline individual responsibilities, specific operating procedures,

training requirements, and specific information on potential safety and health hazards.

The hazards faced by DEECO field personnel are varied, and specific controls of many hazards are

the responsibility of the client. This HSP will enable employees to recognize potential hazards so

that the client may take actions to correct the condition before the work is performed. This HSP also

identifies DEECO activities which may pose significant health and safety risks. 

1.1 Responsibilities

This section details the responsibilities for employees and management in the implementation of the

HSP.

President

The President of DEECO has overall responsibility for compliance with all applicable federal and

state regulations and the provisions of this HSP. Periodic meetings with managers and employees

should be conducted to discuss:

# The importance of health and safety.

# Changes in regulations regarding health and safety.

# Recent employee monitoring results.

# Any recent employee accidents/injuries and possible preventive measures to avoid

a recurrence.

In addition to the above responsibilities, the President is responsible for authorizing any deviations

from the HSP.

Managers

Project managers and field team leaders are responsible for the health and safety of all persons

assigned to the specific project. Project managers and field team leaders must ensure that:

# Employees are properly trained to perform all tasks in a safe manner.

# Proper personal protective equipment are available and in good working condition.

# Persons using personal protective equipment have been instructed on their use.

# Emergency equipment is available and in good working condition.

# Employees are informed of any exposure monitoring performed in their work area

that may be representative of their chemical exposure.

# All safety considerations have been discussed with the client prior to mobilization.

# All aspects of the projects have been discussed and are understood with the team

leader and team members.

# All appropriate safety equipment is available and in good working condition prior to

mobilization.

# All records (employee training, respirator fit-testing, etc.) are present for all team
DEECO Health and Safety Plan Page 2 January 2010

members.

# Copies of MSDSs for all chemicals used by DEECO are available for the client.

# All tasks are performed in a safe manner.

# All accidents, injuries, or spills are reported immediately.

# Any unsafe condition is reported immediately.

# They cooperate with any monitoring surveys.

DEECO Safety Officer

The DEECO Safety Officer (SO) is responsible for the review and maintenance of the Health &

Safety Plan. In addition, the SO is responsible for:

# Identifying when employee exposure monitoring is necessary.

# Writing exposure reports and reporting results to the appropriate department manager

and employees.

# Ensuring that appropriate employee training is provided.

# Investigating reported accidents with department managers.

# Ensuring that new information on health, safety, employee training, or changes in

legal requirements are conveyed to the Director of Field Services. 

1.2 Employee Conduct

Appropriate employee conduct is essential in conveying a professional image to DEECO clients.

When performing work on client premises:

# Dress professionally.

# Contact the team leader if problems with a client arises.

# Discuss disagreements with other DEECO personnel in private, not in front of the

client.

# Do not discuss DEECO company policies or practices with clients (e.g. management,

compensation. etc.)

# Direct all questions regarding sampling or project activities to the team leader.

# Do not convey DEECO in a negative manner to clients. Any disagreements with

company practices should be discussed directly with your manager.

# Do not volunteer data to client employees.

# Release data only to the designated client contact.

# Do not promise a date for the final report. Have the client contact the project

manager or coordinator for a final report date.

# Remain busy while on the client's premises.

# Remain within designated areas of plant site.

# Notify team leader when leaving area.

# Notify client when leaving site for lunch or the end of the day.

# Be on time for client meetings. If problems arise, call the client immediately if the

scheduled time cannot be kept.

# Follow all rules and regulations of the client while on the plant site.

# If approached by the news media, do not offer any information. Refer all questions

to the client.
DEECO Health and Safety Plan Page 3 January 2010

Drugs and Alcohol Use

It is DEECO's desire to provide a drug-free, healthful, and safe workplace. To promote this goal,

employees are required to report to work in appropriate mental and physical condition to perform

their jobs in a satisfactory manner.

While on DEECO premises and while conducting business-related activities off DEECO premises,

no employee may use, possess, distribute, sell, or be under the influence of alcohol or engage in the

unlawful manufacture, distribution, dispensation, possession, or use of illegal drugs. Violations of

this policy may lead to disciplinary action, up to and including immediate termination of

employment, and/or required participation in a substance abuse rehabilitation or treatment program.

Such violations may also have legal consequences.

The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's

ability to perform the essential functions of the job effectively and in a safe manner that does not

endanger other individuals in the workplace.

To inform employees about important provisions of this policy, DEECO has established a drug-free

awareness program. The program provides information on the dangers and effects of substance

abuse in the workplace, resources available to employees, and consequences for violations of this

policy.

Employees with questions or concerns about substance dependency or abuse are encouraged to

discuss these matters with their supervisor or the Personnel Director to receive assistance or referrals

to appropriate resources in the community.

Employees with drug or alcohol problems that have not resulted in, and are not the immediate

subject of, disciplinary action may request approval to take unpaid time off to participate in a

rehabilitation or treatment program through DEECO's health insurance benefit coverage. Leave may

be granted if the employee agrees to abstain from use of the problem substance; abides by all

DEECO policies, rules, and prohibitions relating to conduct in the workplace; and if granting the

leave will not cause DEECO any undue hardship.

Under the Drug-Free Workplace Act, an employee who performs work for a government contract

or grant must notify DEECO of a criminal conviction for drug-related activity occurring in the

workplace. The report must be made within five days of the conviction.

Employees with questions on this policy or issues related to drug or alcohol use in the workplace

should raise their concerns with their supervisor or the Personnel Director without fear of reprisal.

Abusive Language

Abusive or vulgar language, ethnic or sexual slurs and insults will not be tolerated on client or

DEECO premises. Use of such language is not only offensive, but may be seen as illegal

harassment. Inappropriate language or insults can result in immediate, appropriate action upon the

employee by DEECO. If problems with employee use of such language occurs, notify your manager.
DEECO Health and Safety Plan Page 4 January 2010

1.3 Pre-Work Safety Considerations

The Project Coordinator or Manager should determine through a site visit, or through extensive

conversations with the client, if any unusual safety hazards exist at the work site. Additional

equipment, if needed, should be determined by the Project Coordinator/Manager and the DEECO

S.O.

1.4 Employee Safety Education, Training, and Evaluation

All DEECO personnel shall initially receive the equivalent of the OSHA 40-hour Training for

Hazardous Waste Operators. The 8-hour Refresher Training shall be completed annually by all

personnel.

Additional training and education may be required for specific job responsibilities. The training

requirements for additional education shall be set by the President.

Employee Safety Evaluation Program

An annual evaluation of each employee’s safety performance will be conducted.

Evaluating an employee’s safety performance involves measuring the level at which employees are

achieving both their own personal safety goals and the company’s expected safety performance

standards. Integrating health and safety into a performance appraisal system provides management

with a unique opportunity to tie the employee’s accountabilities and achievements to the company’s

objectives and strategic plans. 

The goals of the Employee Safety Evaluation Program are;

1. Communicating information to employees on how well they are meeting the health and

safety performance expectations of their jobs;

2. Identifying areas for coaching to help employees improve their health and safety performance

and develop safe work practices;

3. Providing opportunities to further communicate the organization’s health and safety

performance expectations;

4. Supporting the organizational succession plan;

5. Providing feedback to the organization about its recruitment and selection process as well

as its integrated health and safety training/development program; 

6. Providing feedback about the employee’s perceptions of the company’s health and safety

performance and standards. 

For employees, meeting the health and safety expectations of a job requires them to:

1. Report hazards or hazardous conditions to their supervisor;
DEECO Health and Safety Plan Page 5 January 2010

2. Work in a safe manner at all times by using appropriate protective gear and controls on

equipment;

3. Follow company policies and procedures;

4. Wear personal protective equipment as instructed;

5. Participate in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)

For supervisors, meeting the health and safety expectations of a job requires the ability to: 

1. Coach employees on safe work practices;

2. Enforce company policies and procedures;

3. Act as a positive role model for staff with respect to safe work practices;

4. Support any staff who are members of the joint health and safety committee;

5. Be aware of their legal requirements under the Occupational Health and Safety Act;

6. Review new jobs/tasks/processes/equipment for safety concerns;

7. Follow-up on reported concerns in a timely fashion;

8. Encourage employee input into safety-related concerns and solution-finding processes; and

9. Discipline staff when required for failure to follow safety procedures.

The Employee Safety Evaluation Program will quantify the health and safety areas being monitored

and provide qualitative feedback on employee health and safety performance.

The Employee Safety Evaluation Program will evaluate a employee’s performance on the following;

1. Reporting hazards or hazardous conditions to their supervisor;

2. Working in a safe manner at all times by using appropriate protective gear and controls on

equipment;

3. Following company policies and procedures;

4. Wearing personal protective equipment as instructed;

5. Participating in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)

The Employee Safety Evaluation Program will evaluate a supervisor’s performance on the following;
DEECO Health and Safety Plan Page 6 January 2010

1. Effectiveness in managing health and safety issues in their department or area of

responsibility; and

2. Establishing specific criteria for minimum health and safety standards.
DEECO Health and Safety Plan Page 7 January 2010

2.0 General Safety Requirements

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

safety procedures, field personnel are to follow the procedures which are more stringent. In all cases,

all OSHA, MSHA and/or EPA requirements shall be met.

2.1 First Aid for Accidents and Injuries

In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible in terms

of time and distance to the worksite, which is available for the treatment of injured employees, a

person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American

Red Cross, or equivalent training that can be verified by documentary evidence, shall be available

at the worksite to render first aid. 

First aid supplies shall be easily accessible when required. The contents of the first aid kit shall be

placed in a weatherproof container with individual sealed packages for each type of item, and shall

be checked by the employer before being sent out on each job and at least weekly on each job to

ensure that the expended items are replaced.

Proper equipment for prompt transportation of the injured person to a physician or hospital, or a

communication system for contacting necessary ambulance service, shall be provided.

In areas where 911 is not available, the telephone numbers of the physicians, hospitals, or

ambulances shall be conspicuously posted.

Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable

facilities for quick drenching or flushing of the eyes and body (e.g. safety showers and emergency

eyewash systems) shall be provided within the work area for immediate emergency use. The

location of these facilities for quick drenching or flushing of the eyes and body shall be identified

and all employees in the affected area will be shown the location of these facilities.

The reporting of any work-related accident, illness, or injury is required by Worker's Compensation

regulations. North Carolina law requires that a manager's report on an accident or injury be filed

within 10 days after the incident.

The reporting of incidents will enable employees and management to determine what possible

corrective actions can be taken to avoid a recurrence of the incident.

Responsibilities

Project managers or coordinators must ensure that:

# Immediate care is obtained for all accidents or injuries.

# All employee accidents or injuries are recorded on the DEECO Accident Report form

by the employee.

# Copies of the Accident Report form are sent to the Personnel Director and the

DEECO S.O.
DEECO Health and Safety Plan Page 8 January 2010

# Accident reports are reviewed with the employee and possible preventive measures

are noted and implemented if required.

# Any equipment involved in an incident is removed from service until repaired or

replaced.

The Personnel Director must ensure that:

# Necessary North Carolina forms are completed, distributed, and maintained for any

occupational injury or accident.

# The OSHA Form 300 is updated and posted on the bulletin board in the Break Room.

Employees must ensure that:

# All accidents or injuries are reported immediately to the Department Manager,

Project Manager, or Project Coordinator.

# All details of the accident or injury are recorded on the DEECO Accident Report

form.

2.2 Audit/Inspection Procedures

Safety audits and inspections of all work areas will be conducted periodically by the Safety Officer

or a representative thereof. Procedures for conducting an inspection of a job site will be as follows.

The following items, while not inclusive, are indicators of some of the areas of concern for good job

site safety covered in a routine inspection or audit.

Item Acceptable Not Acceptable NA

Employee Safety Training ( ) ( ) ( )

Safety Manual On site ( ) ( ) ( )

Assigned Responsibilities ( ) ( ) ( )

Confined Space Entry ( ) ( ) ( )

Fire Protection ( ) ( ) ( )

Electrical - GFCI or Grounding Program ( ) ( ) ( )

Equipment Inspection/Maintenance ( ) ( ) ( )

Excavation/Trenching/Shoring ( ) ( ) ( )

Floor/Wall openings ( ) ( ) ( )

Hearing Conservation ( ) ( ) ( )

Housekeeping ( ) ( ) ( )

Mechanical Lifting ( ) ( ) ( )

Mechanical and Electrical Safety ( ) ( ) ( )

Power Tools ( ) ( ) ( )

Scaffolding ( ) ( ) ( )

Stairways and Ladders ( ) ( ) ( )

Travel Safety Followed ( ) ( ) ( )

Thermal Stress ( ) ( ) ( )

Chemical Safety Guidelines Met ( ) ( ) ( )

Hazard Communication Requirements Met ( ) ( ) ( )

Material Safety Data Sheets On site ( ) ( ) ( )

Chemical Labelling Clear and correct ( ) ( ) ( )

Personal Protective Equipment ( ) ( ) ( )
DEECO Health and Safety Plan Page 9 January 2010

Respiratory Protection ( ) ( ) ( )

Gloves ( ) ( ) ( )

Protective Eyewear ( ) ( ) ( )

Protective Clothing ( ) ( ) ( )

Fall Protection ( ) ( ) ( )

2.3 Bloodborne Pathogens

In the normal course of work, it is not reasonably anticipated that DEECO employees will encounter

occupational exposure of the skin, eye, mucous membrane, or parenteral contact with blood or other

potentially infectious materials. Consequently, DEECO is not required to have a written Exposure

Control Plan.

However, in the case of an accident, all contact with blood or blood products should be avoided to

prevent the risk of exposure to bloodborne pathogens, . Cuts, scrapes, and abrasions should be

reported to the safety officer or appointed representative and proper health care should be provided

by trained personnel. Rubber gloves should be worn at all times when treating injuries causing risk

to bloodborne pathogens. 

Rubber gloves, protective resuscitation masks, and other first aid items are contained in the field first

aid kit which is to be present on each project.

2.4 Aerial Devices (Man Lifts)

On occasions, DEECO employees may be required to use aerial devices (man lifts) to access

sampling locations. The following are examples of aerial devices;

1. An aerial device is any vehicle-mounted device, telescoping or articulating, or both, which

is used to position personnel;

2. An aerial ladder is an aerial device consisting of a single- or multiple-section extensible

ladder;

3. An articulating boom platform is an aerial device with two or more hinged boom sections.;

4. An extensible boom platform is an aerial device (except ladders) with a telescopic or

extensible boom. Telescopic derricks with personnel platform attachments shall be

considered to be extensible boom platforms when used with a personnel platform;

5. An insulated aerial device is an aerial device designed for work on energized lines and

apparatus;

5. A mobile unit is a combination of an aerial device, its vehicle, and related equipment;

6. A platform is any personnel-carrying device (basket or bucket) which is a component of an

aerial device;

7. A vehicle is any carrier that is not manually propelled; and
DEECO Health and Safety Plan Page 10 January 2010

8. A vertical tower is an aerial device designed to elevate a platform in a substantially vertical

axis.

Specifc Requirements for Aerial Lifts

Only trained persons shall operate an aerial lift.

For ladder trucks and tower trucks, before the truck is moved for highway travel, aerial ladders will

be secured in the lower traveling position by the locking device above the truck cab, and the

manually operated device at the base of the ladder, or by other equally effective means (e.g., cradles

which prevent rotation of the ladder in combination with positive acting linear actuators).

For extensible and articulating boom platforms, the lift controls shall be tested each day prior to use

to determine that such controls are in safe working condition.

Belting off to an adjacent pole, structure, or equipment while working from an aerial lift shall not

be permitted.

Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge

of the basket or use planks, ladders, or other devices for a work position.

A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial

lift.

Boom and basket load limits specified by the manufacturer shall not be exceeded.

The brakes shall be set and outriggers, when used, shall be positioned on pads or a solid surface.

Wheel chocks shall be installed before using an aerial lift on an incline.

An aerial lift truck may not be moved when the boom is elevated in a working position with men in

the basket, except for equipment which is specifically designed for this type of operation in

accordance with the provisions of OSHA 1910.67, paragraphs (b)(1) and (b)(2).

Articulating boom and extensible boom platforms, primarily designed as personnel carriers, shall

have both platform (upper) and lower controls. Upper controls shall be in or beside the platform

within easy reach of the operator. Lower controls shall provide for overriding the upper controls.

Controls shall be plainly marked as to their function. Lower level controls shall not be operated

unless permission has been obtained from the employee in the lift, except in case of emergency.

Climbers shall not be worn while performing work from an aerial lift.

The insulated portion of an aerial lift shall not be altered in any manner that might reduce its

insulating value.

Before moving an aerial lift for travel, the boom(s) shall be inspected to see that it is properly cradled

and outriggers are in stowed position, except as provided in OSHA 1910.67, paragraph (c)(2)(viii).
DEECO Health and Safety Plan Page 11 January 2010

2.5 Confined Space Entry

A Confined Space in an enclosure having limited access and egress. Examples of confined spaces

include, but are not limited to:

# Storage tanks, tank cars, process vessels, bins, silos, boilers, and other tank-like

compartments usually with only a manhole for entry.

# Open-topped spaces of more than 4 feet in depth, such as pits, vaults and vessels, not

subject to good natural ventilation.

# Septic tanks, sewers, underground utility tunnels, pipelines, and similar structures.

Confined spaces may contain atmospheres that are hazardous to life and health because of the

presence of flammable, explosive, or toxic contaminants or because of either a deficiency or excess

of oxygen. It is DEECO policy not to permit employees to enter a confined space. In the event that

confined space entry is necessary as part of a project, the client is to provide DEECO personnel with

training, life-support equipment, and emergency/rescue personnel during any confined space work.

2.6 Documented Safety Meetings

Safety Meetings will be held on the first day of a project, on-site. A review of safety conditions will

be made by the project manager/field team leader at the end of each day's work. Any unusual or

notable health or safety concerns will be noted in the field log, and discussed with all field team

members. All field safety meetings will be documented in the field log book, and a copy of the

appropriate pages will be included in the final written report to the client.

The President shall ensure that meetings are held periodically to address safety violations,

procedures, and/or updates. The dates, attendees, and topics of these meetings will be documented

and placed in the Safety Meetings file.

2.7 Fire Protection

Every employee should be aware of the combustible characteristics of the chemicals and materials

they use or may come in contact with. This information can be found on the chemical's Material

Safety Data Sheet (MSDS), or labels on the material container.

When performing work on a client's site, the Project Manager or Coordinator must:

# Be able to clearly identify all regular and emergency exits in the building or work

area.

# Receive a site evacuation route from the client.

# Receive emergency notification procedures from the client (e.g. number to call in

case of fire, explosion, etc.).

# Ensure all team members are aware of the above information.

Care should be taken when storing or using chemicals or hazardous materials in DEECO vehicles

or mobile laboratories. All vehicles and mobile laboratories are equipped with fire extinguisher.

If a fire should occur:

# Aim fire extinguisher at the base of the fire.

# Never allow the fire to come between you and an exit.

# Never use water on electrical or burning liquid fires.

If the fire is too large to be contained with one fire extinguisher:
DEECO Health and Safety Plan Page 12 January 2010

# Immediately notify the site emergency contact. Report location of fire, material

burning, and if any injuries are involved.

# Evacuate the area.

Fire Extinguisher Classes

Class A - for use on ordinary combustible materials such as paper, wood, etc.

Class B - for use on flammable and combustible liquids, greases, paints, etc.

Class C - for use on electrical fires.

Class D - for use on combustible metals.

All fire extinguishers located in the DEECO vehicles and mobile laboratories are rated for Class A,

B, and C fires.

2.8 Electrical - GFCI or Grounding Program

It is the policy of DEECO to establish and implement an assured equipment grounding conductor

program on work sites covering all cord sets, receptacles which are not a part of the permanent

wiring of the building or structure, and equipment connected by cord and plug which are available

for use or used by employees. This policy shall apply to all work sites not equipped with ground

fault circuit interrupters in accordance with OSHA standard 1926.400 (h).

The project manager/field team leader shall implement the assured equipment grounding conductor

program where existing and predictable hazards are identifyedi the surrounding area or working

conditions which are unsanitary, hazardous or dangerous to employees, and who is authorized to take

prompt corrective measures to eliminate them.

The project manager/field team leader shall be responsible and accountable for the following:

Each cord set, attachment cap, plug and receptacle of cord set and any equipment connected by cord

and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be

visually inspected before each day's use for external defects, such as deformed or missing pins, or

insulation damage, and for indication of possible internal damage. Equipment found damaged or

defective may not be used until repaired.

The project manager/field team leader is responsible for tests on all cord sets, receptacles which are

not a part of the permanent wiring of the building or structure, and cord and plug connected

equipment repaired to be grounded. Tests shall be documented on the log for assured equipment

grounding conductor program and shall be on the job site for inspection by OSHA officials and any

affected employee. Equipment that does not meet prescribed test shall not be put into service. The

following tests shall be performed:

1. All equipment grounding conductors shall be tested for continuity and shall be electrically

continuous.
DEECO Health and Safety Plan Page 13 January 2010

2. Each receptacle and attachment cap or plug shall be tested for correct attachment of the

equipment grounding conductor. The equipment grounding shall be connected to its

terminal..

In accordance with OSHA Construction Safety and health Standards 1926.21 Safety Training and

Education, project manager/field team leader shall attend such training sessions as the company may

deem necessary.

A copy of this policy shall be at the job site for inspection and copy by OSHA officials and any

affected employee. Management retains the authority to designate that certain jobs comply with

regulation 1926.400 (h) by use of ground fault circuit interrupters in lieu of the program established

above. A copy of the completed forms will be kept on each applicable job site for inspection

purposes.

Electric power operated tools and power cords shall be UL approved, double insulated or have the

third wire ground whole and in place. All 120-volt single phase, 15- and 20-ampere receptacle

outlets on construction sites, which are not a part of the permanent wiring of the building or structure

and which are in use by employees, shall have approved ground-fault circuit interrupters (GFCI) for

personnel protection.

All equipment and power cords are to be inspected prior to the field project. Any equipment or

power cord which is not in proper working order shall be tagged as "DAMAGED-DO NOT USE"

and returned to the DEECO laboratory for repair or replacement.

2.9 Equipment Inspection/Maintenance

Mechanical and electrical equipment will be periodically inspected according to the manufacturers

instructions to ensure they are in proper working order, all cords and parts are not chipped, frayed

or broken, and recommended maintenance procedures are conducted on schedule. Equipment that

does not meet safety standards will be repaired or replaced before use.

2.10 Excavation/Trenching/Shoring

DEECO personnel shall not perform excavation or trenching work, nor shall DEECO personnel be

expected to enter an excavation or trench. Should such entry be required on a project, the client must

ensure:

- Underground lines, equipment and electrical cables shall be located, identified and

de-energized prior to beginning work.

- Walls and faces of trenches and excavations, four or more feet deep, are shored,

sloped or shielded as dictated by the type of soil encountered.

- Daily inspections are conducted by a competent person for evidence of a situation

that could result in possible cave-ins, indications of failure of protective systems or

other hazardous conditions.

- Employees are not be permitted underneath loads handled by lifting or digging

equipment. Employees shall be required to stand away from any vehicle being

loaded or unloaded.
DEECO Health and Safety Plan Page 14 January 2010

- Employees are be protected from excavated or other materials and equipment that

could pose a hazard by falling or rolling in excavations.

 - Physical barriers are be placed around or over trenches and excavations. Barriers

shall be removed only when necessary to provide access to personnel or equipment.

Flashing light barricades shall be provided at night.

- A stairway, ladder, ramp or other safe means of egress is located in trench

excavations that are four feet or more in depth so as to require no more than 25 feet

of lateral travel for employees.

- Backfilling and removal of support systems are performed only after employees have

cleared the area. All excavations shall be backfilled and graded promptly.

- Trenches greater than four feet deep shall require an approved confined space entry

permit.

The client requiring DEECO personnel to enter a trench or excavation shall provide training to

DEECO personnel in accordance to client and OSHA regulations and policies.

2.11 Floor/Wall Openings

With regards to guarding floor and wall openings and holes, workers will comply with 29 CFR

1910.23 and 1926, Subpart M.

General requirements are as follows:

1. Ladderway floor openings shall be guarded by a standard railing and toe-boards or cover.

In general, the railing shall be provided on all exposed sides, except at entrances to stairways.

2. Hatchways and chute floor openings shall be guarded by one of the following:

a. Hinged covers and a standard railing with only exposed side.

b. A removable standard railing with toe-board on not more than two sides and fixed

standard railings with toe boards on all other exposed sides.

3. Temporary floor openings, into which persons can accidentally walk, shall be guarded by

either a standard railing with toe-board on all exposed sides, or a floor hole cover that is

secured against accidental displacement.

4. Wall openings, from which there is a drop of more than four feet, and the bottom of the

opening is less than three feet above the working surface, shall be guarded as follows:

a. A standard rail, if that will effectively reduce the danger of falling. If the bottom of

a wall opening is less than four inches above the working surface, a toe-board or an

enclosing screen shall also be provided.

5. Every open-sided floor or platform four feet or more above adjacent floor or ground level

shall be guarded by a standard railing or equivalent. A toe-board shall be provided wherever,

beneath the open sides, persons can pass or there is moving machinery or there is equipment

with which falling material could create a hazard.
DEECO Health and Safety Plan Page 15 January 2010

Standard Specifications

1. A standard railing shall consist of top rail, intermediate rail, toe-board and posts, and shall

have a vertical height of approximately 42 inches.

a. The intermediate rail shall be halfway between the top rail and the floor, platform

runway or ramp.

b. Posts shall be spaced not more than eight feet on corners.

c. A completed railing structure shall be capable of withstanding a load of at least 200

pounds applied in any direction at any point on the top rail, with a minimum of

deflection.

2. A standard handrail shall be of a construction similar to a standard rail except that it is

mounted on a wall or partition and does not include an intermediate rail.

a. The height to handrails shall not be more than 34 inches or less than 30 inches from

top surface to tread or ramp.

b. Handrails and railings shall be provided with a clearance of approximately three

inches between the rail and any other object.

3. Floor opening covers shall be of any material that meets the following strength requirements:

a. The cover, when located in roadways or vehicular aisles, shall be designed to carry

a truck rear axle load of at least two times the maximum intended load.

b. The floor opening cover shall be capable of supporting the maximum intended load

and so installed as to prevent accidental displacement.

4. Wall opening protection shall meet the following requirements:

a. Barriers shall be of such construction and mounting that, when in place, they are

capable of withstanding a load of at least 200 pounds applied in any direction (except

upward) with a minimum deflection.

5. During the performance of work on low pitched roofs, employees shall be protected at all

open sides and edges by the use of a motion-stopping safety system.

Barricades

1. Signs, signals and barricades shall be posted to detour passage of persons and vehicles at

locations where potential hazards exist.

a. Barricades must be 42 inches high.

b. Barricades should be kept four feet back from the edge of excavations, holes, and

platforms and six feet back from the edge of low-pitched roofs.

c. Barricades with flashing lights shall be provided at night.
DEECO Health and Safety Plan Page 16 January 2010

2. All employees engaged in built-up roofing work will undergo training so that they are able

to recognize and deal with the hazards of falling associated the working near a roof

perimeter.

2.12 Hearing Conservation

DEECO personnel may be exposed to excessive noise levels while on a client's premises. The

project manager/field team leader will ensure all high noise areas have been identified, and that each

member of the field team is aware of the location of these areas. Hearing protection is to be provided

by DEECO to field personnel at no cost. Employees will wear hearing protection as instructed and

in all areas required.

Hearing Conservation Training Program

DEECO will train each employee who is exposed to noise at or above an 8-hour time weighted

average of 85 decibels. DEECO will institute a training program and ensure employee participation

in the program.

The training program will be repeated annually for each employee included in the hearing

conservation program. Information provided in the training program will be updated to be consistent

with changes in protective equipment and work processes.

DEECO will ensure that each employee is informed of the effects of noise on hearing, the purpose

of hearing protectors, the advantages, disadvantages, and attenuation of various types, and

instructions on selection, fitting, use, and care, and the purpose of audiometric testing and an

explanation of the audiometric test procedures.

DEECO will provide annual audiometric exams for all personnel. The President is responsible for

ensuring compliance with applicable regulations (29 CFR 1910.95, "Occupational Noise Exposure",

and 1926.101, "Hearing Protection"). 

Audiometric Testing Program

DEECO will establish and maintain an audiometric testing program by making audiometric testing

available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85

decibels. The program shall be provided at no cost to employees.

Audiometric tests will be be performed by a licensed or certified audiologist, otolaryngologist, or

other physician, or by a technician who is certified by the Council of Accreditation in Occupational

Hearing Conservation, or who has satisfactorily demonstrated competence in administering

audiometric examinations, obtaining valid audiograms, and properly using, maintaining and

checking calibration and proper functioning of the audiometers being used. A technician who

operates microprocessor audiometers does not need to be certified. A technician who performs

audiometric tests must be responsible to an audiologist, otolaryngologist or physician.

All audiograms obtained pursuant to this section shall meet the requirements of OSHA 1910,

Appendix C: "Audiometric Measuring Instruments."
DEECO Health and Safety Plan Page 17 January 2010

Baseline Audiogram

Within 6 months of an employee's first exposure at or above the action level, DEECO will establish

a valid baseline audiogram against which subsequent audiograms can be compared.

Where baseline audiograms are obtained more than 6 months after the employee's first exposure at

or above the action level, employees shall wear hearing protectors for any period exceeding six

months after first exposure until the baseline audiogram is obtained.

Testing to establish a baseline audiogram shall be preceded by at least 14 hours without exposure

to workplace noise. Hearing protectors may be used as a substitute for the requirement that baseline

audiograms be preceded by 14 hours without exposure to workplace noise. DEECO will notify

employees of the need to avoid high levels of non-occupational noise exposure during the 14-hour

period immediately preceding the audiometric examination.

Annual Audiogram

At least annually after obtaining the baseline audiogram, DEECO will obtain a new audiogram for

each employee exposed at or above an 8-hour time-weighted average of 85 decibels.

Evaluation of Audiogram

Each employee's annual audiogram will be compared to that employee's baseline audiogram to

determine if the audiogram is valid and if a standard threshold shift (as defined in OSHA

1910.95(g)(10)) has occurred. This comparison may be done by a technician.

If the annual audiogram shows that an employee has suffered a standard threshold shift, DEECO will

obtain a retest within 30 days and consider the results of the retest as the annual audiogram.

An audiologist, an otolaryngologist, or a physician will review problem audiograms and will

determine whether there is a need for further evaluation. DEECO will provide to the person

performing this evaluation, a copy of the requirements for hearing conservation as set forth in OSHA

1910.95 paragraphs (c) through (n), the baseline audiogram and most recent audiogram of the

employee to be evaluated, measurements of background sound pressure levels in the audiometric test

room as required in OSHA 1910Appendix D: Audiometric Test Rooms, and records of audiometer

calibrations required by OSHA 1910 paragraph (h)(5).

Follow-up Procedures

If a comparison of the annual audiogram to the baseline audiogram indicates a standard threshold

shift, the employee will be informed of this fact in writing, within 21 days of the determination.

Unless a physician determines that the standard threshold shift is not work related or aggravated by

occupational noise exposure, DEECO will ensure that the employees not using hearing protectors

will be fitted with hearing protectors, trained in their use and care, and required to use them.

Employees already using hearing protectors shall be refitted and retrained in the use of hearing

protectors and provided with hearing protectors offering greater attenuation if necessary.
DEECO Health and Safety Plan Page 18 January 2010

The employee will be referred for a clinical audiological evaluation or an otological examination,

as appropriate, if additional testing is necessary or if DEECO suspects that a medical pathology of

the ear is caused or aggravated by the wearing of hearing protectors.

The employee will be informed of the need for an otological examination if a medical pathology of

the ear that is unrelated to the use of hearing protectors is suspected.

If subsequent audiometric testing of an employee whose exposure to noise is less than an 8-hour

TWA of 90 decibels indicates that a standard threshold shift is not persistent, DEECO will inform

the employee of the new audiometric interpretation and mMay discontinue the required use of

hearing protectors for that employee.

Revised Baseline

An annual audiogram may be substituted for the baseline audiogram when, in the judgment of the

audiologist, otolaryngologist or physician who is evaluating the audiogram, that the standard

threshold shift revealed by the audiogram is persistent or the hearing threshold shown in the annual

audiogram indicates significant improvement over the baseline audiogram.

2.13 Housekeeping

Employees shall maintain a high standard of housekeeping on the job at all times as an integral part

of the work The purpose of this requirement is to ensure the safety of all personnel entering the lob

location and to maintain a condition of housekeeping that is consistent with the desired appearance

of a DEECO job location.

Project managers/field team leaders shall clean up work areas daily, store all equipment and

construction materials in an orderly manner in storage areas. Barricades shall be used for temporary

storage of equipment and construction materials. All scrap construction materials and waste shall

be picked up and disposed of at least daily. All location procedures for waste disposal shall be

followed. Form wood and other lumber shall be neatly stored when not in use. All nails shall be

removed or bent over to prevent puncture wounds.

All stairways, walkways, ladder cages and scaffolds shall be kept clear of all cords, cables, hosed,

materials and anything else that might hinder personnel access. Cords, cables and hosed at stairways,

walkways and scaffolds will be supported at least seven feet overhead or laid flat outside of

walkways.

All spills of oil, solvents, chemicals and any regulated liquids shall be reported to the site

representative immediately and shall be properly cleaned up and disposed of. Dumping of these

materials in floor drains, sanitary sewers, storm sewers. drainage ditches, or other open ground is

forbidden.

Employees shall be responsible for keeping all location roads free from all debris resulting from their

performance of the work. Storage of combustible and flammable materials shall not be located under

overhead pipelines and utilities. Loose materials on roofs or other overhead structures shall be

removed or secured to prevent being blown or bumped off. Accumulation of materials that may
DEECO Health and Safety Plan Page 19 January 2010

create a fire hazard shall not be permitted. Storage of materials shall be at least eight feet from the

center of railroad tracks.

Project managers/field team leaders shall perform a housekeeping review of the work site at the end

of each day. All concerns noted will be corrected prior to the field team leaving the site.

2.14 Manual Lifting

When lifting heavy objects, an improper lifting technique may result in a serious injury. When

lifting objects, ensure that you:

# Know your limitation. Enlist help before lifting objects that are beyond your

strength.

# Have cleared a path to carry the object, before lifting the object.

# Lift with your legs, keeping your back straight.

# Have a firm grip and a sure footing before lifting the object.

# Lift objects gradually. Avoid jerking motions and awkward positions.

# Avoid twisting your body when carrying the object. Turn your entire body with the

object.

2.15 Mechanical Lifting

Mechanical lifting aids, such as hoists, trucks, dollies, and jacks are to be used to assist Field

personnel in handling heavy objects. Field personnel must ensure that:

# The rated capacity of the mechanical device is not exceeded.

# When lifting objects to a higher work location, the area below the lifted object is kept

clear by restricting access using ropes, barricades, or other barriers.

# Loads are not left suspended in the air. Raise the load only when it can be unloaded

at its destination.

# Attempts are not made to catch or grab falling objects.

2.16 Mechanical and Electrical Safety

Analytical Equipment

The use and repair of analytical equipment can present unusual electrical and mechanical hazards.

Before performing work on any piece of equipment:

# Ensure that power has been disconnected from the unit.

# Ensure that any reserve power (capacitors, batteries) are de-energized before working

on unit.

# Do not remove any piece of equipment labelled "Trained Service Personnel Only".

Call the appropriate service organization for repair of the unit.

Additional mechanical and electrical hazards may exist. Employees must be aware of all hazards

before performing any repair work. Employees should consult the client's representative before

connecting transformers or other electrical lines to power supplies. See Lockout/Tagout procedures

in the Supplement of this manual.
DEECO Health and Safety Plan Page 20 January 2010

2.17 New Employee Orientation

All new employees will undergo initial safety training which includes assigned responsibilities, first

aid procedures (including bloodborne pathogens procedures), accident response and reporting

procedures, emergency action plan and spill procedures, fire protection, general safety rules, and

housekeeping. Subsequent safety training will be provided based on job description.

2.18 Power and Hand Tools

Improper use of power and hand tools can lead to serious injuries. Field personnel should be familiar

with the tools used and their operating manuals. Field personnel should ensure that:

# Tools are used for the propose for which they were designed.

# Power tools must be either grounded or double-insulated.

# Defective or damaged tools must be labelled and stored such that other employees

will not mistakenly use the tool.

# Safety glasses with side shields or goggles must be worn when using power tools that

may produce projectiles.

2.19 Process Safety Management

Many client locations will be required to provide DEECO (the contract employee) with process

safety management (PSM) information. The processes that require PSMs involves a flammable

liquid or gas (as defined in OSHA 1926.59(c)) on site in one location, in a quantity of 10,000 pounds

(4535.9 kg) or more except for hydrocarbon fuels used solely for workplace consumption as a fuel

(e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part

of a process containing another highly hazardous chemical covered by this standard and flammable

liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point

without benefit of chilling or refrigeration. PSM describes the procedures for preventing or

minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive

chemicals. These releases may result in toxic, fire or explosion hazards

The DEECO project manager/field team leader shall ensure that all DEECO employees understand

and follow these procedures.

Management of Change

DEECO work activities at client’s facility may impact on the operation of a PSM regulated process.

The DEECO project manager/field team leader and the client’s facility representative will perform

an initial process hazard analysis (hazard evaluation) on processes covered. The process hazard

analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control

the hazards involved in the process as they relate to DEECO’s work activities. The client’s facility

representative shall determine and document the priority order for conducting process hazard

analyses based on a rationale which includes such considerations as extent of the process hazards,

number of potentially affected employees, age of the process, and operating history of the process.

The process hazard analysis must be conducted before any work by DEECO is conducted.
DEECO Health and Safety Plan Page 21 January 2010

2.20 Scaffolding

Scaffold Erection and Inspection

It is DEECO’s policy not to erect scaffolding. Scaffolding is typically the responsibility of the

client. Scaffolds shall be designed by a qualified person and shall be constructed and loaded in

accordance with that design. Scaffolds shall be erected, moved, dismantled, or altered only under

the supervision and direction of a competent person qualified in scaffold erection, moving,

dismantling or alteration. Such activities shall be performed only by experienced and trained

employees selected for such work by the competent person.

Each day before using any scaffolding, ensure that the scaffolding has been inspected by a person

qualified in scaffold inspection. 

General Requirements for Scaffolding Use

1. The footing or anchorage for scaffolds shall be sound, rigid and capable of carrying the

maximum intended load without settling or displacement.

2. Guardrails and toe-boards shall be installed on all open sides and ends of scaffold platforms

more than four feet above the ground or floor.

3. Scaffolds shall be provided with an access ladder or equivalent safe access.

4. Employees shall not climb or work from scaffold handrails, mid-rails or brace members.

5. When free-standing manually propelled mobile scaffolds are used, the height shall not

exceed four times the minimum base dimension.

a.Employees shall not ride on mobile scaffolds when they are being moved.

6. All scaffolds shall be inspected by a competent person prior to use and shall be acceptancetagged.

7. Employees who erect scaffolds shall be trained in the proper means of building scaffolds.

8. Employees using scaffolds shall be trained in the safe use of scaffolds.

The project manager/field team leader must ensure that all scaffolding is erected in accordance with

OSHA regulations and the items listed above. 

The project manager/field team leader must check with client's representative to see if additional fall

protection is required when working on scaffolding.

Scaffold Use Training

DEECO shall have each employee who performs work while on a scaffold trained by a person

qualified in the subject matter to recognize the hazards associated with the type of scaffold being

used and to understand the procedures to control or minimize those hazards. The training shall

include the following areas, as applicable:

1. The nature of any electrical hazards, fall hazards and falling object hazards in the work area;

2. The correct procedures for dealing with electrical hazards and for erecting, maintaining, and

disassembling the fall protection systems and falling object protection systems being used;
DEECO Health and Safety Plan Page 22 January 2010

3. The proper use of the scaffold, and the proper handling of materials on the scaffold; and

4. The maximum intended load and the load-carrying capacities of the scaffolds used.

Additional training will be provided when changes in the types of scaffolds, fall protection, falling

object protection, or other equipment present a hazard about which an employee has not been

previously trained or when inadequacies in an affected employee's work involving scaffolds indicate

that the employee has not retained the requisite proficiency.

2.21 Stairways and Ladders

With regards to stairways and ladders, employees should follow 29 CFR 1910.25, 26, and 27,

"Portable Wood Ladders, "Portable Metal Ladders, and Fixed Ladders", and 1926 Subpart X,

"Stairways and Ladders".

General Requirements

1. A stairway or ladder shall be provided at all personnel points of access where there is a break

in elevation of 19 inches or more, and no ramp, runway, sloped embankment or personnel

hoist is provided.

2. A double-cleated ladder or two or more separate ladders shall be provided when ladders are

the only means of access or egress from a working area for 25 or more employees, or when

the ladder is to serve simultaneous two-way traffic.

3. When a building or structure has only one point of access between levels, that point of access

shall be kept clear to permit free passage of employees.

Stairways

1. Stairways that will not be a permanent part of the structure on which construction work is

being performed shall have landings of not less than 30 inches in the direction of travel and

extend at least 22 inches in width at every 12 feet or less of vertical rise.

2. Riser height and tread depth shall be uniform within each flight of stairs.

3. Where doors or gates open directly on a stairway, a platform shall be provided, and the swing

of the door shall not reduce the effective width of the platform to less than 20 inches.

4. Slippery conditions on stairways shall be eliminated before the stairways are used to reach

other levels.

5. Except during stairway construction, foot traffic shall be prohibited on skeleton metal stairs

where the treads and landings are to be filled in at a later date, unless the stairs are fitted with

secured temporary treads and landings long enough to cover the entire tread and landing area.

6. Stairways having four or more risers or rising more than 30 inches, whichever is less, shall

be equipped with at least one handrail and one system along each unprotected side or edge.

7. Stairrails shall be not less than 36 inches from the upper surface of the strairrail system to the

surface of the tread.

8. Mid-rails, screens, mesh, intermediate vertical members, or equivalent intermediate structural

members, shall be provided between the top rail of the stairrail system and the stair\way

steps.
DEECO Health and Safety Plan Page 23 January 2010

9. Handrails and the top rails of stairrail systems shall be capable of withstanding a force of at

least 200 pounds applied within two inches of the top edge, in any downward or outward

direction, at any point along the top edge.

10. Fixed stairways shall conform to the requirements of 29 CFR 1919.24 "Fixed Industrial

Stairs".

Ladders

1. Portable ladders shall be capable of supporting at least four times the maximum intended

load.

2. Portable metal or conductive ladders shall not be used near energized lines or equipment

except as may be necessary in specialized work such as high voltage substations where nonconductive ladders might present a greater hazard than conductive ladders. Conductive or

metal ladders shall be prominently marked a conductive and all necessary precautions shall

be taken when used in specialized work.

3. Ladder rungs, cleats and steps shall be parallel, level and uniformly spaced when the ladder

is in position for use.

4. The minimum clear distance between side rails for all portable ladders shall be 11.5 inches.

5. The following requirements apply to the use of all ladders, including job-made ladders.

a. Ladders used for access to an upper landing surface, shall have side rails that extend

at least three feet above the landing surface.

b. Ladders shall be maintained free of oil, grease and other slipping hazards.

c. Ladders shall be used only for the purpose for which they were designed.

d. Non-self-supporting ladders shall be used at an angle such that the horizontal

distance from the top support to the foot of the ladder is approximately one-quarter

of the working length of the ladder.

e. Non-self-supporting ladders shall be tied off or otherwise secured to prevent

accidental displacement.

f. When ascending or descending a ladder, the user shall face the ladder and shall use

at least one hand to grasp the ladder. The user shall not carry any object or load that

could cause him/her to lose balance and fall.

6. Ladders with structural defects, such as broken or missing rungs, shall be tagged DO NOT

USE, and shall be withdrawn from service.

7. Ladders will be inspected by a competent person and approved for use before being put into

service. Each user shall visually inspect ladder before using.

8. Ladders placed in any location where they can be displaced by workplace activities or traffic,

shall have warning signs posted.

Extension Ladders

1. After the extension section has been raised to desired height, the safety latches must be

engaged and the extension rope secured to a rung on the base section of the ladder before use.

2. Extension ladder sections are not to be used separately.

Stepladders

1. Must be set level on all four feet, with spreaders locked on place. Do not use as a straight

ladder.
DEECO Health and Safety Plan Page 24 January 2010

2. When used close to the edge of an elevated platform, roof or floor opening, and when

location requirements so specify, they must be tied off, and employees using such a

stepladder shall wear fall-arresting equipment.

3. Employees using stepladders shall stand so that their waists are below the top of the ladder.

The President shall ensure that all employees are trained in the proper use of ladders. 

2.22 Travel Safety

When driving any DEECO vehicle, or when driving your own personal vehicle when performing

DEECO related work, employees must:

# Obey all traffic rules and regulations.

# Obey all traffic rules on a plant site.

# Turn off vehicle and set brake when leaving vehicle.

# Use horn at blind driveways or intersections with an obstructive view.

# Have a valid North Carolina license to operate a DEECO vehicle and trailer.

# Never pick up hitchhikers.

# Perform a pre-trip check of vehicle(s) lights, horns, brakes, oil, etc.

2.23 Thermal Stress

Thermal stress to the body can be caused when the body temperature is not in balance between body

heat production and heat loss to the surrounding environment. Heat stress is caused when the body

is unable to sufficiently cool the body, and cold stress is possible when the body is unable to

sufficiently heat the body.

Heat Stress

Heat stress is a general term used to describe various degrees of heat illness. The temperature of the

body is a function of the amount of heat it produces and the amount of heat it can lose. When the

temperature of the environment approaches the body temperature, it becomes increasingly difficult

for the body to lose heat. Heat illness is possible when the body is not able to sufficiently cool itself.

The body can lose heat to the environment by three mechanisms. The most important is convection.

This is when the temperature of the skin is higher than that of the surrounding atmosphere.

Conduction is the transfer of heat from the body to a solid or liquid. An example would be the

immediate cooling of your face on a hot day by splashing cold water on it. Both convection and

conduction can also be negative, meaning that if the atmosphere or material in contact with the body

is warmer than the body itself, heat can be transferred to the body.

The third, and comparably small, mechanism is respiration. This is the warming and saturation of

respired air while in the lungs.

Effects of Heat

The body possesses two physiological responses which enable it to lose heat. The first is the dilation

(enlargement) of the blood vessels near the skin surface. This increases the flow of blood,

transferring heat to the skin. The skin temperature will increase, and is cooled by either convection

on conduction.
DEECO Health and Safety Plan Page 25 January 2010

The second response is sweating. Sweating occurs when the increase in blood flow to the skin does

not achieve the desired cooling effect. Heat is lost when sweat is evaporated from the body.

Heat Illness

Heat illness can be caused by either elevated body or skin temperatures. Elevated body temperatures

can result in heat exhaustion, heat cramps, and heat stroke. Elevated skin temperatures can cause

skin-tissue damage.

Heat Exhaustion

Heat exhaustion is caused by circulatory failure, where the amount of blood returned to the heart is

significantly reduced. Symptoms of heat exhaustion are fatigue, headache, dizziness, loss of

appetite, nausea, abdominal pain, vomiting, shortness of breath, and pulse rates in excess of 150

beats per minute. Heat exhaustion can result in poor judgement, irritability, and possibly fainting.

A person suffering from heat exhaustion can usually recover very quickly if he/she is removed to a

cool place and allowed to lie down.

Heat Cramps 

Heat cramps are muscle spasms which usually occur in the arms, legs, back and abdomen. This is

due to excessive loss of salt from sweating. Heat cramps can be prevented by taking extra salt when

heavy work is carried out. It is recommended that employees do not take salt tablets, but rather

ensure that they eat at regular intervals during the course of the work, Extra salt can by added to the

body through eating.

Heat Stroke

The most serious heat illness is heat stroke. When the body temperature reaches a certain level,

sweating may stop. This will cause the body temperature to increase to critical levels. Such an

increase in body temperature can cause denaturization of proteins, enzyme degradation, changes in

the viscosity of cell protoplasm, and alterations in the physical structure of the cell membranes.

Tissue damage and death are possible.

Immediate medical attention is necessary for individuals suffering from heat stroke in order to avoid

irreversible damage to the brain. The individual should be wrapped in cool, wet sheets. Immersion

in a cold bath is not recommended, since a too rapid decrease in the body temperature may result in

tissue damage.

Precautions

1. Water intake must equal the amount of water lost due to sweating and excretion. In hot

environments, water intake must be forced since the body's normal thirst mechanism is not

adequate to force the individual to drink. Continuous sweat rates of 1 to 2 liters per hours

are not unusual.

2. Salt is lost during sweating. Additions of small amounts of salt to food may be necessary.

3. Most importantly, frequent, short breaks during strenuous activities allows the body to better

adapt to the hot environment than infrequent long breaks. By taking shorter breaks, there is

less cumulative fatigue and less demand on the heart and respiration.

4. It is possible for the body to acclimatize to hot environments. This may happen only if

successive days are spent in the hot environment (usually between 4 to 7). 
DEECO Health and Safety Plan Page 26 January 2010

Cold Stress

In cold environments, the body must increase its metabolic heat production. In general, -30 EF is

the lower limit for prolonged work. Unlike hot environments, individuals do not acclimatize

(physiologically adapt) to cold environments.

The wind-chill temperature, rather than the ambient temperature, best describe a cold environment.

Wind velocity adds to the rate of body cooling.

Cold Illness

Hypothermia

Hypothermia is a general cooling of the body temperature. Hypothermia can occur in environments

above 32 EF. Symptoms include excessive shivering, and numbness in extremities. The individual

should be moved to a warm environment. Alcohol should not be consumed, since this will cause

the blood vessel to dilate, resulting in excessive body heat loss. Hot, non-alcoholic beverages should

be administered.

Frost Bite

Frost bite can be either superficial or can penetrate below the skin. Superficial frost bite can be

easily treated by warming the exposed skin with hands or other warmer part of the body (e.g. placing

hands under armpits). This will gradually warm the skin. Rapid warming (exposure to fire, soaking

in cold water etc.) is not recommended since damage to the skin tissue can occur. It is important to

note that pain will occur as the skin is thawed.

When frost bite extends below the surface of the skin (from prolonged exposure), it is essential to

get immediate medical attention.

Precautions

1. Individuals should eat balanced meals and replace body liquids regularly. Dehydration is as

prevalent in cold environments as it is in hot environments. Warm liquids are preferable

since they do not have to be warmed by the body after being consumed.

2. Proper protective clothing should be worn when exposed to cold environments. 

3 Dexterity and judgement are both diminished in cold environments.

2.24 Welding and Cutting

DEECO employees shall not perform any welding or cutting on a project site. The project

manager/field team leader shall ensure that the client contracts such work with qualified individuals.

DEECO employees shall leave the immediate area during any welding or cutting operations.

2.26 Lockout/Tagout (LOTO)

Lockout/Tagout (LOTO) refers to specific practices and procedures to safeguard employees from

the unexpected energization or startup of machinery and equipment, or the release of hazardous

energy during service or maintenance activities. Under no circumstance should DEECO

employee’s participate in LOTO. Should any LOTO be necessary at a client’s facility, all LOTO

procedures are to be handled by the client or their representative.
DEECO Health and Safety Plan Page 27 January 2010

2.27 Fall Protection

2.27.1 Determining When Fall Protection Must be Provided

DEECO shall determine if the walking/working surfaces on which its employees are to work have

the strength and structural integrity to support employees safely. Employees shall be allowed to work

on those surfaces only when the surfaces have the requisite strength and structural integrity.

Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected

side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by

the use of guardrail systems, safety net systems, or personal fall arrest systems.

Hoist Areas

Each employee in a hoist area shall be protected from falling 6 feet (1.8 m) or more to lower levels

by guardrail systems or personal fall arrest systems. If guardrail systems, [or chain, gate, or guardrail]

or portions thereof, are removed to facilitate the hoisting operation (e.g., during landing of

materials), and an employee must lean through the access opening or out over the edge of the access

opening (to receive or guide equipment and materials, for example), that employee shall be protected

from fall hazards by a personal fall arrest system.

Holes

Each employee on walking/working surfaces shall be protected from falling through holes (including

skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or

guardrail systems erected around such holes.

Each employee on a walking/working surface shall be protected from tripping in or stepping into or

through holes (including skylights) by covers.

Each employee on a walking/working surface shall be protected from objects falling through holes

(including skylights) by covers.

Formwork and Reinforcing Steel

Each employee working on the face of formwork or reinforcing steel shall be protected from falling

6 feet (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or

positioning device systems.

Ramps, Runways, and Other Walkways

Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8

m) or more to lower levels by guardrail systems.
DEECO Health and Safety Plan Page 28 January 2010

Excavations

Each employee at the edge of an excavation 6 feet (1.8 m) or more in depth shall be protected from

falling by guardrail systems, fences, or barricades when the excavations are not readily seen because

of plant growth or other visual barrier.

Each employee at the edge of a well, pit, shaft, and similar excavation 6 feet (1.8 m) or more in depth

shall be protected from falling by guardrail systems, fences, barricades, or covers.

Dangerous Equipment

Each employee less than 6 feet (1.8 m) above dangerous equipment shall be protected from falling

into or onto the dangerous equipment by guardrail systems or by equipment guards.

Each employee 6 feet (1.8 m) or more above dangerous equipment shall be protected from fall

hazards by guardrail systems, personal fall arrest systems, or safety net systems.

Overhand Bricklaying and Related Work

Currently, DEECO does not perform overhand bricklaying, so any fall protection programs related

to overhand brick are not applicable.

Working on Roofs

Each employee engaged in any activities on low-slope roofs (slope less than 4 in 12), with

unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling

by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning

line system and guardrail system, warning line system and safety net system, or warning line system

and personal fall arrest system, or warning line system and safety monitoring system.

Each employee on a steep roof (slope greater than 4 in 12) with unprotected sides and edges 6 feet

(1.8 m) or more above lower levels shall be protected from falling by guardrail systems with

toeboards, safety net systems, or personal fall arrest systems.

Precast Concrete Erection

Currently, DEECO does not perform precast concrete erection, so any fall protection programs

related to precast concrete erection are not applicable.

Residential Construction

Currently, DEECO does not perform residential construction, so any fall protection programs related

to residential construction are not applicable.
DEECO Health and Safety Plan Page 29 January 2010

Wall Openings

Each employee working on, at, above, or near wall openings (including those with chutes attached)

where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and

the inside bottom edge of the wall opening is less than 39 inches (1.0 m) above the walking/working

surface, shall be protected from falling by the use of a guardrail system, a safety net system, or a

personal fall arrest system.

Walking/Working Surfaces Not Otherwise Addressed (e.g Man Lifts)

When operating or working on any man lifts that fall under the ANSI standard definition that

includes certain vehicle-mounted elevating and rotating work platforms, namely "extensible boom

platforms," "aerial ladders," "articulating boom platforms," "vertical towers," and "a combination

of any of the above.", DEECO employees shall be protected from falling by a personal fall arrest

system.

For all other walking/working surfaces not otherwise addressed, each employee on a

walking/working surface 6 feet (1.8 m) or more above lower levels shall be protected from falling

by a guardrail system, safety net system, or personal fall arrest system.

Protection from Falling Objects

When an employee is exposed to falling objects, the employer shall have each employee wear a hard

hat and shall erect toeboards, screens, or guardrail systems to prevent objects from falling from

higher levels, erect a canopy structure and keep potential fall objects far enough from the edge of the

higher level so that those objects would not go over the edge if they were accidentally displaced; or,

barricade the area to which objects could fall, prohibit employees from entering the barricaded area,

and keep objects that may fall far enough away from the edge of a higher level so that those objects

would not go over the edge if they were accidentally displaced.

The project manager/field team leader must check with client's representative to see if additional

barricade procedures specific to their facility are required.

2.27.2 Guidelines for Fall Protection

The DEECO project manager/field team in conjunction with the client's representative shall

determine when additional fall protection is required.

The client shall provide and install all Guard Rail Systems, Safety Net Systems, Positioning Device

Systems and Warning Line Systems required for DEECO an employee, and shall comply with all

other pertinent requirements of described below before that employee begins the work that

necessitates the fall protection.

Guardrail Systems 

Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus

or minus 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of
DEECO Health and Safety Plan Page 30 January 2010

the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria

of this paragraph.

Note: When employees are using stilts, the top edge height of the top rail, or equivalent member,

shall be increased an amount equal to the height of the stilts.

Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural

members shall be installed between the top edge of the guardrail system and the walking/working

surface when there is no wall or parapet wall at least 21 inches (53 cm) high.

Midrails, when used, shall be installed at a height midway between the top edge of the guardrail

system and the walking/working level.

Screens and mesh, when used, shall extend from the top rail to the walking/working level and along

the entire opening between top rail supports.

Intermediate members (such as balusters), when used between posts, shall be not more than 19

inches (48 cm) apart.

Other structural members (such as additional midrails and architectural panels) shall be installed

such that there are no openings in the guardrail system that are more than 19 inches (.5 m) wide.

Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds

(890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at

any point along the top edge.

When the 200 pound (890 N) test load specified above is applied in a downward direction, the top

edge of the guardrail shall not deflect to a height less than 39 inches (1.0 m) above the

walking/working level.

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural

members shall be capable of withstanding, without failure, a force of at least 150 pounds (666 N)

applied in any downward or outward direction at any point along the midrail or other member.

Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or

lacerations, and to prevent snagging of clothing.

The ends of all top rails and midrails shall not overhang the terminal posts, except where such

overhang does not constitute a projection hazard.

Steel banding and plastic banding shall not be used as top rails or midrails.

Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diameter or thickness to

prevent cuts and lacerations. If wire rope is used for top rails, it shall be flagged at not more than 6-

foot intervals with high-visibility material.

When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall

be placed across the access opening between guardrail sections when hoisting operations are not

taking place.
DEECO Health and Safety Plan Page 31 January 2010

When guardrail systems are used at holes, they shall be erected on all unprotected sides or edges of

the hole.

When guardrail systems are used around holes used for the passage of materials, the hole shall have

not more than two sides provided with removable guardrail sections to allow the passage of

materials. When the hole is not in use, it shall be closed over with a cover, or a guardrail system shall

be provided along all unprotected sides or edges.

When guardrail systems are used around holes which are used as points of access (such as

ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into

the hole.

Guardrail systems used on ramps and runways shall be erected along each unprotected side or edge.

Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected as frequently

as necessary to ensure that it continues to meet the strength requirements of paragraph (b)(3) of this

section.

Safety Net Systems

Safety nets shall be installed as close as practicable under the walking/working surface on which

employees are working, but in no case more than 30 feet (9.1 m) below such level. When nets are

used on bridges, the potential fall area from the walking/working surface to the net shall be

unobstructed.

Safety nets shall extend outward from the outermost projection of the work surface as follows:

Vertical distance from working level to

horizontal plane of net

Minimum required horizontal distance of

outer edge of net from the edge of the

working surface

Up to 5 feet 8 feet

More than 5 feet up to 10 feet 10 feet

More than 10 feet 13 feet

Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface

or structures below when subjected to an impact force equal to the drop test described below. Safety

nets and their installations shall be capable of absorbing an impact force equal to that produced by

the drop test described below.

Except as described below, safety nets and safety net installations shall be drop-tested at the jobsite

after initial installation and before being used as a fall protection system, whenever relocated, after

major repair, and at 6-month intervals if left in one place. The drop-test shall consist of a 400 pound

(180 kg) bag of sand 30 + or - 2 inches (76 + or - 5 cm) in diameter dropped into the net from the

highest walking/working surface at which employees are exposed to fall hazards, but not from less

than 42 inches (1.1 m) above that level.
DEECO Health and Safety Plan Page 32 January 2010

When the employer can demonstrate that it is unreasonable to perform the drop-test, the employer

(or a designated competent person) shall certify that the net and net installation is in compliance with

the provisions of paragraphs (c)(3) and (c)(4)(i) of this section by preparing a certification record

prior to the net being used as a fall protection system. The certification record must include an

identification of the net and net installation for which the certification record is being prepared; the

date that it was determined that the identified net and net installation were in compliance with

paragraph (c)(3) of this section and the signature of the person making the determination and

certification. The most recent certification record for each net and net installation shall be available

at the jobsite for inspection.

Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear,

damage, and other deterioration. Defective components shall be removed from service. Safety nets

shall also be inspected after any occurrence which could affect the integrity of the safety net system.

Materials, scrap pieces, equipment, and tools which have fallen into the safety net shall be removed

as soon as possible from the net and at least before the next work shift.

The maximum size of each safety net mesh opening shall not exceed 36 square inches (230 cm) nor

be longer than 6 inches (15 cm) on any side, and the opening, measured center-to-center of mesh

ropes or webbing, shall not be longer than 6 inches (15 cm). All mesh crossings shall be secured to

prevent enlargement of the mesh opening.

Each safety net (or section of it) shall have a border rope for webbing with a minimum breaking

strength of 5,000 pounds (22.2 kN).

Connections between safety net panels shall be as strong as integral net components and shall be

spaced not more than 6 inches (15 cm) apart.

Personal Fall Arrest Systems

Personal fall arrest systems shall consist of a full body harness. Body belts are not acceptable as part

of a personal fall arrest system except in a positioning device system as described below.

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall

have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to

interfacing parts of the system.

Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds (22.2 kN) and shall

be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or

taking permanent deformation.

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent

unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected

member, or shall be a locking type snaphook designed and used to prevent disengagement of the

snaphook by the contact of the snaphook keeper by the connected member. Only locking type

snaphooks shall be used.
DEECO Health and Safety Plan Page 33 January 2010

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall

not be engaged directly to webbing, rope or wire rope, to each other, to a dee-ring to which another

snaphook or other connector is attached, to a horizontal lifeline; or to any object which is

incompatibly shaped or dimensioned in relation to the snaphook such that unintentional

disengagement could occur by the connected object being able to depress the snaphook keeper and

release itself.

On suspended scaffolds or similar work platforms with horizontal lifelines which may become

vertical lifelines, the devices used to connect to a horizontal lifeline shall be capable of locking in

both directions on the lifeline. Horizontal lifelines shall be designed, installed, and used, under the

supervision of a qualified person, as part of a complete personal fall arrest system, which maintains

a safety factor of at least two.

Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds (22.2 kN).

Lifelines shall be protected against being cut or abraded. Self-retracting lifelines and lanyards which

automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a

minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanyard

in the fully extended position.

Self-retracting lifelines and lanyards which do not limit free fall distance to 2 feet (0.61 m) or less,

ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum

tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully

extended position.

Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and

body harnesses shall be made from synthetic fibers.

Anchorages used for attachment of personal fall arrest equipment shall be independent of any

anchorage being used to support or suspend platforms and capable of supporting at least 5,000

pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as part of a

complete personal fall arrest system which maintains a safety factor of at least two and under the

supervision of a qualified person.

Personal fall arrest systems, when stopping a fall, shall limit maximum arresting force on an

employee to 900 pounds (4 kN) when used with a body belt, limit maximum arresting force on an

employee to 1,800 pounds (8 kN) when used with a body harness, be rigged such that an employee

can neither free fall more than 6 feet (1.8 m), nor contact any lower level, bring an employee to a

complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m)

and, have sufficient strength to withstand twice the potential impact energy of an employee free

falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is

less.

The attachment point of the body belt shall be located in the center of the wearer's back. The

attachment point of the body harness shall be located in the center of the wearer's back near shoulder

level, or above the wearer's head.

Body belts, harnesses, and components shall be used only for employee protection (as part of a

personal fall arrest system or positioning device system) and not to hoist materials.
DEECO Health and Safety Plan Page 34 January 2010

Personal fall arrest systems and components subjected to impact loading shall be immediately

removed from service and shall not be used again for employee protection until inspected and

determined by a competent person to be undamaged and suitable for reuse.

The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that

employees are able to rescue themselves.

Personal fall arrest systems shall be inspected prior to each use for wear, damage and other

deterioration, and defective components shall be removed from service.

Body belts shall be at least one and five-eighths (1 5/8) inches (4.1 cm) wide.

Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to

hoists. When a personal fall arrest system is used at hoist areas, it shall be rigged to allow the

movement of the employee only as far as the edge of the walking/working surface.

Positioning Device Systems

Positioning device systems shall be rigged such that an employee cannot free fall more than 2 feet

(.9 m). Positioning devices shall be secured to an anchorage capable of supporting at least twice the

potential impact load of an employee's fall or 3,000 pounds (13.3 kN), whichever is greater.

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall

have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to

interfacing parts of this system. Connecting assemblies shall have a minimum tensile strength of

5,000 pounds (22.2 kN).

Dee-rings and snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN)

without cracking, breaking, or taking permanent deformation. 

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent

unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected

member, or shall be a locking type snaphook designed and used to prevent disengagement of the

snaphook by the contact of the snaphook keeper by the connected member. As of January 1, 1998,

only locking type snaphooks shall be used.

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall

not be engaged directly to webbing, rope or wire rope, to each other, to a dee-ring to which another

snaphook or other connector is attached, to a horizontal lifeline; or to any object which is

incompatibly shaped or dimensioned in relation to the snaphook such that unintentional

disengagement could occur by the connected object being able to depress the snaphook keeper and

release itself.

Positioning device systems shall be inspected prior to each use for wear, damage, and other

deterioration, and defective components shall be removed from service.

Body belts, harnesses, and components shall be used only for employee protection (as part of a

personal fall arrest system or positioning device system) and not to hoist materials.
DEECO Health and Safety Plan Page 35 January 2010

Warning Line Systems

Warning line systems shall be erected around all sides of the roof work area. When mechanical

equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the

roof edge. When mechanical equipment is being used, the warning line shall be erected not less than

6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment

operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction

of mechanical equipment operation.

Points of access, materials handling areas, storage areas, and hoisting areas shall be connected to the

work area by an access path formed by two warning lines. When the path to a point of access is not

in use, a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line,

shall be placed across the path at the point where the path intersects the warning line erected around

the work area, or the path shall be offset such that a person cannot walk directly into the work area.

Warning lines shall consist of ropes, wires, or chains, and supporting stanchions erected as follows:

1. The rope, wire, or chain shall be flagged at not more than 6-foot (1.8 m) intervals with highvisibility material;

2. The rope, wire, or chain shall be rigged and supported in such a way that its lowest point

(including sag) is no less than 34 inches (.9 m) from the walking/working surface and its

highest point is no more than 39 inches (1.0 m) from the walking/working surface;

3. After being erected, with the rope, wire, or chain attached, stanchions shall be capable of

resisting, without tipping over, a force of at least 16 pounds (71 N) applied horizontally

against the stanchion, 30 inches (.8 m) above the walking/working surface, perpendicular to

the warning line, and in the direction of the floor, roof, or platform edge;

4. The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and

after being attached to the stanchions, shall be capable of supporting, without breaking, the

loads applied to the stanchions as described above; and

5. The line shall be attached at each stanchion in such a way that pulling on one section of the

line between stanchions will not result in slack being taken up in adjacent sections before the

stanchion tips over.

No employee shall be allowed in the area between a roof edge and a warning line unless the

employee is performing roofing work in that area.

Mechanical equipment on roofs shall be used or stored only in areas where employees are protected

by a warning line system, guardrail system, or personal fall arrest system.

Controlled Access Zone

When used to control access to areas where leading edge and other operations are taking place the

controlled access zone shall be defined by a control line or by any other means that restricts access.
DEECO Health and Safety Plan Page 36 January 2010

When control lines are used, they shall be erected not less than 6 feet (1.8 m) nor more than 25 feet

(7.7 m) from the unprotected or leading edge, except when erecting precast concrete members.

DEECO does not erecting precast concrete members. The control line shall extend along the entire

length of the unprotected or leading edge and shall be approximately parallel to the unprotected or

leading edge. The control line shall be connected on each side to a guardrail system or wall.

Additional control lines shall be erected at each end to enclose the controlled access zone.

Control lines shall consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions.

Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with

high-visibility material. Each line shall be rigged and supported in such a way that its lowest point

(including sag) is not less than 39 inches (1 m) from the walking/working surface and its highest

point is not more than 45 inches (1.3 m) from the walking/working surface. Each line shall have a

minimum breaking strength of 200 pounds (.88 kN).

Safety Monitoring Systems

DEECO shall designate a competent person as the safety monitor. The safety monitor will monitor

the safety of other employees. The safety monitor shall be competent to recognize fall hazards. The

safety monitor shall warn the employee when it appears that the employee is unaware of a fall hazard

or is acting in an unsafe manner. The safety monitor shall be on the same walking/working surface

and within visual sighting distance of the employee being monitored. The safety monitor shall be

close enough to communicate orally with the employee. The safety monitor shall not have other

responsibilities which could take the monitor's attention from the monitoring function.

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being

used to monitor employees engaged in roofing operations on low-slope roofs. No employee, other

than an employee engaged in roofing work [on low-sloped roofs] or an employee covered by a fall

protection plan, shall be allowed in an area where an employee is being protected by a safety

monitoring system.

Each employee working in a controlled access zone shall be directed to comply promptly with fall

hazard warnings from safety monitors.

Covers

Covers located in roadways and vehicular aisles shall be capable of supporting, without failure, at

least twice the maximum axle load of the largest vehicle expected to cross over the cover. All other

covers shall be capable of supporting, without failure, at least twice the weight of employees,

equipment, and materials that may be imposed on the cover at any one time. All covers shall be

secured when installed so as to prevent accidental displacement by the wind, equipment, or

employees. All covers shall be color coded or they shall be marked with the word "HOLE" or

"COVER" to provide warning of the hazard.

Protection from Falling Objects

Toeboards, when used as falling object protection, shall be erected along the edge of the overhead

walking/working surface for a distance sufficient to protect employees below. Toeboards shall be
DEECO Health and Safety Plan Page 37 January 2010

capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any

downward or outward direction at any point along the toeboard. Toeboards shall be a minimum of

3 1/2 inches (9 cm) in vertical height from their top edge to the level of the walking/working surface.

They shall have not more than 1/4 inch (0.6 cm) clearance above the walking/working surface. They

shall be solid or have openings not over 1 inch (2.5 cm) in greatest dimension. Where tools,

equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall

be erected from the walking/working surface or toeboard to the top of a guardrail system's top rail

or midrail, for a distance sufficient to protect employees below. Guardrail systems, when used as

falling object protection, shall have all openings small enough to prevent passage of potential falling

objects.

Canopies, when used as falling object protection, shall be strong enough to prevent collapse and to

prevent penetration by any objects which may fall onto the canopy.

Fall Protection Plan

This option is available only to employees engaged in leading edge work that it is infeasible or it

creates a greater hazard to use conventional fall protection equipment. 

The fall protection plan shall be prepared by a qualified person and developed specifically for the

site where the leading edge work, precast concrete work, or residential construction work is being

performed and the plan must be maintained up to date. Any changes to the fall protection plan shall

be approved by a qualified person. A copy of the fall protection plan with all approved changes shall

be maintained at the job site. The implementation of the fall protection plan shall be under the

supervision of a competent person. The fall protection plan shall document the reasons why the use

of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets

systems) are infeasible or why their use would create a greater hazard.

The fall protection plan shall include a written discussion of other measures that will be taken to

reduce or eliminate the fall hazard for workers who cannot be provided with protection from the

conventional fall protection systems. For example, the employer shall discuss the extent to which

scaffolds, ladders, or vehicle mounted work platforms can be used to provide a safer working surface

and thereby reduce the hazard of falling.

The fall protection plan shall identify each location where conventional fall protection methods

cannot be used. These locations shall then be classified as controlled access zones. Where no other

alternative measure has been implemented, the employer shall implement a safety monitoring

system.

The fall protection plan must include a statement which provides the name or other method of

identification for each employee who is designated to work in controlled access zones. No other

employees may enter controlled access zones.

In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the

employer shall investigate the circumstances of the fall or other incident to determine if the fall

protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement

those changes to prevent similar types of falls or incidents.
DEECO Health and Safety Plan Page 38 January 2010

2.27.3 Fall Protection Training Program

DEECO shall provide a training program for each employee who might be exposed to fall hazards.

The program shall enable each employee to recognize the hazards of falling and shall train each

employee in the procedures to be followed in order to minimize these hazards.

DEECO shall assure that each employee has been trained, as necessary, by a competent person

qualified in the nature of fall hazards in the work area, the correct procedures for erecting,

maintaining, disassembling, and inspecting the fall protection systems to be used, the use and

operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems,

safety monitoring systems, controlled access zones, and other protection to be used, the role of each

employee in the safety monitoring system when this system is used, the limitations on the use of

mechanical equipment during the performance of roofing work on low-sloped roofs, the correct

procedures for the handling and storage of equipment and materials and the erection of overhead

protection; and the role of employees in fall protection plans.

Certification of Training

DEECO shall verify compliance with the Fall Protection Training Program by preparing a written

certification record. The written certification record shall contain the name or other identity of the

employee trained, the date(s) of the training, and the signature of the person who conducted the

training or the signature of the employer. If training is conducted by another employer, the

certification record shall indicate the date the employer determined the prior training was adequate

rather than the date of actual training.

The latest training certification shall be maintained.

Retraining

When DEECO has reason to believe that any affected employee who has already been trained does

not have the understanding and skill required by the Fall Protection Training Program, DEECO shall

retrain each such employee. Circumstances where retraining is required include, but are not limited

to, situations where changes in the workplace render previous training obsolete, changes in the types

of fall protection systems or equipment to be used render previous training obsolete, or inadequacies

in an affected employee's knowledge or use of fall protection systems or equipment indicate that the

employee has not retained the requisite understanding or skill.

2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen

Monitors 

For safe operation around processes involving combustible materials, a hot work permit may be

required. Hot work permits (HWPs) are required for any process where testing activities may

produce an ignition source in a work area in which flammable vapors or gases may be present. To

issue an HWP, a hazard assessment must be performed. To do so, combustible gas and vapor

concentrations must be determined for the work area and job classification in question, then

compared to acceptable standards. These surveys typically involve the use of combustible gas

meters-also called lower explosive limit (LEL) meters. These surveys are conducted by the client

personnel issuing the hot work permits .
DEECO Health and Safety Plan Page 39 January 2010

To perform the surveys properly, the facility will have work instructions and standard operating

procedures (SOPs) developed, implemented and documented. Training in LEL instrument use,

instrument calibration, sampling strategy, continuous or follow-up monitoring, tracking of denied

permits, communication between departments related to the content of processes, documentation of

results, auditing of hot work permit procedures and results, and the continuous improvement of those

SOPs will be addressed. 

In some cases DEECO will be required to provide additional monitoring for LEL, carbon monoxide,

hydrogen sulfide, and/or oxygen. For these situations, DEECO personnel will be trained in LEL,

carbon monoxide, hydrogen sulfide, and/or oxygen instrument use and instrument calibration.

Training in Instrument Use

Thorough, documented training will be performed for the use of LEL, carbon monoxide, hydrogen

sulfide, and/or oxygen meters. Thus, training programs for operators of LEL, carbon monoxide,

hydrogen sulfide, and/or oxygen meters will include:

1. Work instructions for basic instrument use;

2. Theory of instrument operation;

3 Instrument maintenance and calibration; and 

4. Recordkeeping for calibration and maintenance.

Instrument Calibration

The instrument manufacturers detail procedures for calibrating LEL, carbon monoxide, hydrogen

sulfide, and/or oxygen meters will be followed. Calibration includes;

1. Clean air-zero point calibration;

2. Calibration of response with the appropriate span gas;

3. Checking and calibration, for actively pumped meters, of the air flow rate in the system;

4. Fault detection and subsequent maintenance; and

5. Record keeping.

Any decisions made to extend the period between calibrations or to lessen the rigor of calibrations

must first be formally evaluated by qualified persons against the manufacturer's recommendations,

industry best practices and governmental regulations. Requirements for specified, periodic

calibration of zero, span and flow are mandates, not recommendations. This applies for all systems,

but is especially critical for systems used in environments where air contaminants that may degrade

the meter's sensing element may be present.
DEECO Health and Safety Plan Page 40 January 2010

For gases and vapors other than those for which a device was calibrated, the manufacturer's

instructions and correction curves should be consult. Variations in response that may result in

incorrect readings from such interferences as:

1. Oxygen concentration;

2. Gas pressure;

3. Sensor poisons (i.e., silicon, silicates and organic lead, acid gases) and sensor depressants

(i.e., chlorinated hydrocarbons, acid gases); and

4. The fact that no reading will occur, or is even possible, for the detection of combustible

airborne mists or dusts, such as lubricating oils, coal dust or grain dust.

The portion of the calibration that deals with instrument airflow rate must include the blocked flow

alarm must being tested before and after each use. While this is a requirement for all such systems,

it is especially critical for instruments used in dusty environments.

Sampling Strategy

Measurement of values for each atmospheric parameter should be made for at least the minimum

response time of the instrument. When monitoring operations involving a descent into atmospheres

that may be stratified, the atmospheric envelope should be tested a distance of approximately four

feet in the direction of travel and to each side. If a sampling probe is used, the rate of progress

should be slowed to accommodate the sampling speed and detector response .

Any reading greater than zero should be followed by an assessment to:

1. Determine the source of the flammable vapors;

2. Eliminate the source, if possible; and

3. Ensure control of the source so that concentrations will not exceed (at most) 10% of the LEL

at any location where it is possible that an ignition source may be present.

Continuous or Follow-Up Monitoring

Continuous or follow-up monitoring may be required under conditions where the process, sequence

of work instructions or ambient conditions might reasonably be expected to change in a manner that

might increase the concentration of flammable gas or vapor. If conditions change during the course

of the permit period in a way that presents or could present additional hazards, then work will be

terminated until the area or conditions are made safe and permit conditions are re-evaluated.

Processes that may affect the composition, concentration, flow rate or volume, pressure and/or

temperature of flammable liquids, vapors or gases;

1. Processes adjacent to the process at which hot work is being performed;
DEECO Health and Safety Plan Page 41 January 2010

2. Ambient conditions such as temperature, wind direction and wind speed; and 

3. Other factors, such as the presence of uncontrolled vehicular traffic and/or ignition sources.

Documentation of Results (Record Keeping)

Each monitor obtained by DEECO will be assign a unique equipment identification (control) number

and complete records, including periodic performance, calibration and maintenance checks will be

maintained. 

2.29 Emergency Response/Evacuation Program

While at a client’s facility, follow their Emergency Response/Evacuation Program. The project

manager/field team leader will ensure that the employees are aware of the facilities’ Emergency

Response/Evacuation Program. Their plan should address the following;

1. Procedures for reporting a fire or other emergency;

2. Procedures for emergency evacuation, including type of evacuation and exit route

assignments;

3. Procedures to account for all employees after evacuation (head count);

4. Procedures to be followed by employees performing rescue or medical duties; and

5. The name or job title of every employee who may be contacted by employees who need more

information about the plan or an explanation of their duties under the plan.

Otherwise, when working at DEECO’s office, the following Emergency Response/Evacuation

procedures should be followed;

1. Report a fires or other emergencies by dialing 911. Administer first aid and/or CPR if you

trained. Do not attempt to fight any fires unless you have been trained in the use of fire

extinguishers;

2. Should an evacuation be necessary follow the escape route assignments. Exit diagrams are

place throughout the office to identify the escape routes to be followed by employees from

each specific facility location. Assist in the evacuation of any visitors and contractors; 

3. Account for employees after the evacuation to ensure that everyone got out. Designated

employees will sweep areas, checking offices and rest rooms, before being the last to leave

a workplace or conducting a roll call in the assembly area; and

4. Account for any visitors and contractors using the Visitors and Contractors Sign In Log.
DEECO Health and Safety Plan Page 42 January 2010

2.30 Compressed Air Systems

DEECO employees are not allowed to operate pneumatic power tools or use the compressed air

systems, air hoses, or air lines associated with pneumatic power tools.

2.31 Concrete Construction

DEECO employees are not allowed perform any concrete work, as described in OSHA 1926.700-

706.

2.32 Powder-Actuated Tools

DEECO employees are not allowed to use powder-actuated tools, as described in OSHA 1926.302

(e).
DEECO Health and Safety Plan Page 43 January 2010

3.0 Chemical Safety Guidelines

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

safety procedures, Field personnel are to follow the procedures which are more stringent. In all

cases, all OSHA and/or EPA requirements shall be met.

Field personnel are to refer to the Material Safety Data Sheet and chemical labels for specific

procedures and handling requirements. Copies of MSDSs for each chemical used, as well as for each

chemical Field personnel may be exposed to while on a client's site, must be made available. The

client is responsible for ensuring that MSDSs for chemicals used on the work site are available for

review. All Field personnel should refer to these MSDSs and be familiar with the properties and

handling requirements of all chemicals that may be used or encountered.

The required level of personal protective equipment for specific chemical hazards discussed in the

following sections depends on the situations at the work site. Decisions on the appropriate

equipment to be worn should be made by the project manager or coordinator.

The following information is DEECO's Chemical Hygiene Plan. Its intent is to protect laboratory

employees from health hazards associated with the use of hazardous chemicals in our laboratory and

to assure that our laboratory employees are not exposed to substances in excess of the permissible

exposure limits as defined by OSHA in 29 CFR 1910 subpart Z.

The plan is available to all employees fro review and a copy will be located in the Health and Safety

files. The plan will be reviewed annually by the Health and Safety Officer and/or the directors of

DEECO.

The following sections of this document and throughout the manual are standard operating

procedures for which each DEECO employee has received adequate training and direction. If

questions exist for the following information, it may be found throughout this manual or in our

memo file. It is the responsibility of each employee to be aware of DEECO's standard operating

procedures for the following:

Accidents, spills, avoidance of routine exposure, choice of chemicals, eating-drinking-smoking,

equipment and glassware, horseplay, mouth suction, personal apparel, housekeeping, personal

protection, planning, unattended operations, use of the hood, waste disposal and storage, working

alone, corrosives, fires, explosions, low temperature, pressurized and vacuum operations,

compressed gasses, chemical storage.

The following operations shall be performed in the LABORATORY FUME HOOD:

- Use of solvents unless in outdoor work areas

- Use of open flames or burning devices

- Use of any organic or inorganic chemical or compound that is unstable

These include preparation of standards, transfer of solvents, disposal or consolidation of waste 
DEECO Health and Safety Plan Page 44 January 2010

Respirators shall be used in accordance with DEECO's respiratory protection policy and with the

OSHA respirator standard 29 CFR 1910.134. This policy and associated documentation is filed in

the office of the Health and Safety Officer and/or safety files.

Appropriate protective apparel compatible with the required degree of protection for substances

handled shall be used. The Health and Safety Officer is available to advise employees on glove,

gown, eye protection, barrier creams, etc, use. Permeability Charts are available in any safety catalog

such as Lab Safety Supply, or SAFECO. Use of tradenames or references does not indicate a

recommendation or approval of listed products or Companies.

All eyewash stations are clearly marked and identified by the use of green placards and red arrows

leading to the eyewash areas. Employees who need to use the eyewashes are instructed as to their

use and must irrigate for a minimum of 15 minutes and seek medical assistance immediately.

Eyewashes will be inspected by the safety officer every month.

Employees have been issued a memorandum as to the procedures to follow for fires and explosions.

Exit routes are marked in each employee area. 

Fume hoods will be inspected every six months by the Health and Safety Officer. Adequacy of face

velocity will be determined by the use of a propeller anemometer and must reach a minimum of 200

fpm. An employee may request a hood inspection at any time should they suspect a problem with

the hood or ventilation system.

No employee will work with any hazardous chemicals unless they have been instructed by their

project manager or health and safety officer. These chemicals include; carcinogens, explosives,

neurotoxins, reproductive damaging chemicals, or acutely hazardous chemicals.

DEECO shall provide, to affected employees, medical attention including follow-up examinations

which MEDFIRST or another approved medical office determines is necessary under the following

circumstances.

a. whenever an employee develops signs and/or symptoms associated with a hazardous

chemical to which they may have been exposed, the employee shall be provided an

opportunity to receive appropriate medical examination. The employee shall contact the

Health and Safety Officer to initiate the medical program.

b. Where exposure monitoring reveals an exposure level routinely above the OSHA action level

(AL) (or in the absence of an action level, exposure above the OSHA permissible exposure

level (PEL)) for OSHA regulated substances for which there are medical monitoring

requirements, medical surveillance shall be established for that employee. Listed OSHA

standard medical surveillance requirements include the chemical benzene, formaldehyde,

methylene chloride.

c. Whenever an event takes place in the laboratory or work area such as a spill, leak, explosion,

or other occurrence resulting in the likelihood of a hazardous exposure, the affected

employee, laboratory or custodial, shall be provided an opportunity for a medical

consultation. This consultation is for the purpose of determining the need for a medical

examination.
DEECO Health and Safety Plan Page 45 January 2010

All aspects of these examinations are provided by a licensed physician, or supervised by a licensed

physician. These examinations are provided without cost to the employee, without loss of pay, and

at a reasonable time and place.

The Health and Safety Officer who is also the Chemical Hygiene Officer will provide information

to the physician:

1. Identity of the hazardous chemical to which the employee may have been exposed.

2. A description of the conditions of the exposure including exposure date if available

3. A description of the signs and symptoms of exposure that the employee is experiencing (if

any).

The physician's written opinion shall include:

1. Recommendations for future medical follow-up

2. Results of examination and associated tests

3. Any medical condition revealed that may place the employee at increased risk as the result

of a chemical exposure.

4. A statement that the employee has been informed by the physician of the results and told of

any medical conditions that may require additional examination of treatment.

3.1 General Characteristics

Routes of Entry

There are three major routes through which chemicals can enter the body and potentially cause harm.

Inhalation: Contaminants in the air can be absorbed into the bloodstream directly through the

lungs. In this manner, the contaminant can be carried to any organ in the body.

Ingestion: Ingestion of chemicals may severely damage the tissues of the digestive tract, damage

the stomach or other organs. The chemical can be absorbed into the bloodstream, or other body

fluids, and carried to other organs in the body.

Skin Absorption: The skin can act as a protective barrier to many chemical agents. However, many

chemicals can penetrate the skin. In this manner, the chemicals can enter the bloodstream and be

distributed throughout the body. Wounds on the skin (e.g. cuts and abrasions) offer a direct route

for chemicals to enter the bloodstream.

Physical Characteristics of Chemicals

Below are definitions of terms used in the following Chemical Safety Sections. Additional

definitions are located in the Guide to Common MSDS Terms, located in Appendix C.

Gas - a formless fluid which takes the shape of its container.

Vapor - the gaseous form of a substance which is normally a solid or liquid at room

temperature.

Fog - a visible, liquid aerosol.

Mist - a "fog" where the liquid particles are large enough to be individually seen.

Fume - particle formed by the condensation of vaporized solids.
DEECO Health and Safety Plan Page 46 January 2010

Dust - solid particles, capable of temporary suspension in air.

Smoke - airborne particles generated from incomplete combustion processes.

Carcinogen - a substance capable of causing cancer in animals or humans.

Mutagen - a substance capable of changing the genetic material in a living cell.

Fetotoxin - a substance capable of causing death or injury to fetus.

Teratogen - a substance which can cause deformations in a fetus from exposure of a

pregnant female.

Health Hazards

Substances to which field employees may be exposed have the potential to cause severe injury or

illnesses. The degree of injury or illness is a function of the exposure; that is the amount of the

substance and the time that an employee is in contact with it. Below are descriptions of various types

of health hazards that may exist when working with hazardous substances.

Irritant: Several chemicals may be an irritant to the skin, eyes, or respiratory tract. Irritation can

range from mild discomfort to severe and irreversible chemical burns on the skin or eyes. Examples

of irritants include ammonia, acids, bases, and several solvents.

Sensitizer: A chemical that is a sensitizer may not elicit a response after one exposure. After

repeated exposures, however, a severe reaction may occur, not necessarily at the point of contact.

The reaction may be a skin rash, or in the case of toluene diisocyanate, failure of the respiratory

system, Examples of sensitizers are formaldehyde, poison ivy, potassium dichromate.

Narcotic: Narcotics cause a depression of the central nervous system, producing a sleepy or dizzy

effect. Narcotics may make an employee unable to perform his/her work. Other safety hazards arise

when employees affected by a narcotic attempt to continue to work. Most organic solvents can

produce narcotic effects.

Asphyxiant: An asphyxiant reduces the amount of oxygen available for use by the body. This can

cause suffocation, leading to coma or even death. There are two types of asphyxiants. A Simple

Asphyxiant reduces the amount of oxygen in an area. Examples of simple asphyxiants include

carbon dioxide, nitrogen, argon, and other inert gases. A second type of asphyxiant is called a

Chemical Asphyxiant. A chemical asphyxiant enters the body through the lungs, and competes with

oxygen for space in the red blood cells. With these asphyxiants, suffocation can occur even if there

is plenty of oxygen in the room. Examples of chemical asphyxiants include carbon monoxide, and

cyanide gas.

Systemic Poison of Toxin: A systemic poison or toxin is a substance that produces an affect away

from the point of contact. For instance carbon tetrachloride can be inhaled or absorbed through the

skin, but exhibits its major effects upon the liver and kidneys.

It is important to remember that different chemicals react differently with the body. Several

chemicals exhibit more than one effect. The employee must review the MSDS for the specific

chemical he/she is working with to fully understand all of the potential hazards.
DEECO Health and Safety Plan Page 47 January 2010

3.2 Acids

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Acids are corrosive substances having a pH < 7.0.

2. Acid vapors and fumes can cause irritation of the eyes, skin, and respiratory tract.

3. Chemical burns on tissue can occur if acids are allowed to contact skin, eyes, or lungs.

4. Severe gastrointestinal pain and tissue injury can occur if acids are ingested.

Symptoms of Overexposure

Hazards of exposure are mainly from acute (short duration) exposures. Effects of acid fumes

or vapors include eye, throat, nose, or lung irritation. Skin or eye contact with acids may

result in severe chemical burns.

First Aid

In the event that acid comes in contact with your skin or eyes:

# Proceed immediately to the nearest eyewash station. Call for assistance from a coworker if necessary.

# Flush the affected area with copious amounts of water for at least 15 minutes. If

contact was with eye, pull the eyelid up and out, exposing the cornea, while flushing

with water.

# Notify the project manager or coordinator and seek medical attention.

If acid is spilled on your clothing:

# Remove contaminated clothing immediately.

# Flush skin area with water for 15 minutes.

# Notify the manager or coordinator and seek medical attention.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Protective Clothing (Saranex Tyvek Suits)

3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or

Organic Vapor/Acid Gas Cartridges.

4. Eyewear - Minimum of safety glasses with side shields. Recommend chemical splash

goggles.

3.3 Bases

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Bases are corrosive substances having a pH > 7.0.

2. Vapors and fumes generated from bases can cause irritation of the eyes, skin, and respiratory

tract.
DEECO Health and Safety Plan Page 48 January 2010

3. Chemical burns can occur if bases are allowed to contact skin or eyes. Bases can cause

irreversible damage to the eyes, even in dilute concentrations.

4. Severe gastrointestinal pain and tissue injury can occur if bases are ingested.

Symptoms of Overexposure

Hazards of exposure are mainly from acute (short duration ) exposures. Effects of alkali

fumes or vapors include eye, throat, nose, or long irritation. Skin or eye contact with bases

may result in severe chemical burns.

First Aid

In the event that a base comes in contact with your skin or eyes: 

# Proceed immediately to the nearest eyewash station. Call for assistance from a coworker if necessary.

# Flush the affected area with copious amounts of water for at least 15 minutes. If

contact was with eye, pull the eyelid up and out, exposing the cornea.

# Notify the project manager or coordinator and seek medical attention.

If a base is spilled on your clothing:

# Remove contaminated clothing immediately.

# Flush skin area with water for 15 minutes.

# Notify the project manager or coordinator and seek medical attention.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Protective Clothing (Saranex Tyvek Suits)

3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or

Organic Vapor/Acid Gas Cartridges.

4. Eyewear - Minimum of safety glasses with side shields. Recommend chemical splash

goggles.

3.4 Compressed Gases

Potential Hazards

Routes of Entry - Inhalation, Contact

1. Cylinders may explode if heated above 135 EF or dropped, damaging the valve stem.

2. Fire Hazards may exist if a Flammable Gas, Oxygen or other oxidizing gas cylinder is placed

near an open flame.

3 Skin and eye burns may result if direct contact with an escaping gas is made.

4. Suffocation can occur if the concentration of a gas is allowed to decrease the percent of

oxygen in an area.

5. If Oxygen is allowed to be released, it may be absorbed into clothing and take as long as 15

minutes to disperse. This could lead to a flash clothing fire if the person comes in contact

with an ignition source.

6. Severe burns may result from skin or eye contact with cryogenic gases.
DEECO Health and Safety Plan Page 49 January 2010

7. Prolonged breathing of oxygen can be toxic.

8. A fire or explosion hazard may exist when using nitrogen and helium, since these gases can

condense oxygen from the air, creating an oxygen-rich environment at the location of the gas.

Symptoms of Overexposure

Symptoms of overexposure to compressed gases depends on the specific gas. Refer to the

MSDS of the gas for this information.

General Handling Procedures

1. Cylinders should be tagged with a FULL, IN USE, or EMPTY Status Tag at all times.

2. Cylinders must have the valve protection cap in place when being moved.

3. Cylinders shall be stored such that they are protected from excessive heat or open flame (125

EF), physical shock, and electrical circuits.

4. Cylinders shall be secured using a chain or strap, to a wall, bench or other firm support.

5. Never completely empty a gas cylinder.

6. Never use oil on regulator valves or connections. Oil can degrade the regulator diaphragm,

contaminate the gas, or be oxidized in air to form explosive products.

7. Use only CGA (Compressed Gas Association) approved regulators and fittings for the

specific gas being used. Do not mix a given regulator with different gases.

8. Do not tamper with manufacturer's safety devices or check valves.

9. Leak-test all fittings and connections using an appropriate leak-test solution.

10. Jewelry should not be worn when handling or using cryogens.

11. If a cylinder should develop a leak:

# Remove all sources of spark or flame.

# Place in exhausted enclosure or remove to a safe outdoor area.

# Identify the cylinder as "Leaking Cylinder". Notify the supplier.

# For Flammable Gases, attach a control valve to the cylinder valve and allow the gas

to escape. Adjust to a moderate discharge rate.

12. If a cylinder containing cryogenic gases is dropped:

# Evacuate area within 100-ft radius of cylinder;

# Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel

relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is

venting gas, do not approach until there is no further discharge.

# When emission from the cylinder has not been noticed for 15 minutes, carefully open

the vent valve and the gas withdrawal valve to empty the cylinder. Move away from

the cylinder after opening valves.

# Once emptied, place in upright position. Write "Dropped Cylinder" on the cylinder

status tag and notify the supplier.

First Aid

If skin or eye contact occurs, flush area with unheated water and apply cold compresses.
DEECO Health and Safety Plan Page 50 January 2010

Personal Protective Equipment

Safety glasses should be worn at a minimum. Cryogenic gloves should be worn if contact with a

cryogenic gas is possible.

3.5 Cryogenic Materials

Cryogenic materials are substances that are kept at very low temperatures (less than 100 EF).

Cryogenics may be liquids or solids. Atmospheric gases, such as nitrogen, oxygen, or hydrogen, that

are cooled to temperatures less than 150 EF become liquified and are examples of cryogenic

materials. "Dry Ice" is another example of a super-cooled gas, carbon dioxide.

Potential Hazards

Routes of Entry - Contact, Inhalation

1. Severe burns may result from skin or eye contact with cryogenic materials.

2. Some liquid gases can deplete the available oxygen in a room Suffocation can result if not

used in a well-ventilated area.

3. Prolonged breathing of pure oxygen may have harmful physiological effects.

4. Nitrogen and helium can condense oxygen from the air, creating an oxygen-rich environment

at the location of the gas. This could be a fire or explosion hazard.

5. Cryogenic gases are stored under high pressure. This creates the same potential hazards as

other compressed gases (see Section 3.4).

6. Hydrogen is extremely flammable and is a fire and explosion hazard.

7. Liquid oxygen, while not flammable itself, does increase the flammability of ordinary

combustibles.

General Handling Procedures

1. When there is the potential for contact with a cryogenic material, a full face shield will be

required. In addition, a lab coat and gloves suitable for cold material handling shall be worn.

2. Jewelry should not be worn when handling or using cryogens.

3. When handling cryogens, trousers should not have cuff.

4. Use tongs to remove objects that are immersed in cryogenic liquids. Never use your hands,

even if wearing gloves!!

5. Use only in well-ventilated areas.

6. Store away from flammable and combustible materials.

7. Do not use near open flame or spark-producing equipment.

Emergency Procedures

1. If skin or eye contact occurs, flush area with unheated water and apply cold compresses.

Notify your supervisor and seek medical attention.

2. If a cylinder containing cryogenic gases is dropped:

# Evacuate area within 100-ft radius of cylinder;
DEECO Health and Safety Plan Page 51 January 2010

# Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel

relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is

venting gas, do not approach until there is no further discharge.

# When emission from the cylinder has not been noticed for 15 minutes, carefully open

the vent valve and the gust withdrawal valve to empty the cylinder. Move away from

the cylinder after opening valves.

# Once emptied, place in upright position. Write "Dropped Cylinder" on the cylinder

status tag and notify the supplier.

3.6 Flammable Liquids and Gases

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Flammable liquids and gases pose significant fire and explosion hazards.

2. Many flammable liquids:

# Can be readily absorbed through the skin.

# Can cause dermatitis.

# Are systemic poisons once in the body.

3. Eye, skin and respiratory tract irritation may occur.

4. Many flammable liquids and gases can produce depression of the central nervous system

(decreases motor response, dizziness, etc.)

Systems of Overexposure

Symptoms of overexposure to flammable liquids and gases will depend on the specific

substance. Refer to the MSDS of the chemical for this information.

General Procedures

1. Keep flammable materials away from open flame, sparks, or excessive heat.

2. Keep away from oxidizing agents such as oxygen.

3. Store in chemical cabinet, isolated from other chemicals.

4. Keep combustible material such as wood, cloth, and paper out of storage cabinets.

5. Do not leave containers of flammable materials in work areas overnight. Return all bottles

to the proper storage cabinet.

6. Flammable liquids and gases should be used only in well ventilated areas.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove

contaminated clothing. Seek medical attention.

2. In the event of a burn; extinguish flames by applying a fire blanket, or rolling on the floor.

Do not attempt to fan out the flames.

3. Use only an approved fire extinguisher to extinguish flames. Do not use water on flammable

liquid fires. Pouring water on these fires may only spread the flames over a wider area.
DEECO Health and Safety Plan Page 52 January 2010

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.

3.7 Organic Solvents

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Solvents can cause skin, eye and respiratory tract irritation.

2. Solvents may cause defatting of the skin, which lessens the ability of the skin to protect

against other chemicals.

3. Some solvents are also systemic toxins and can produce effects on the liver, kidneys, and

other organs if allowed to be absorbed through the skin.

4. Inhalation of solvent vapors may produce narcotic or anesthetic effects, and depression of

the central nervous system.

5. Many organic solvents are also flammable.

Symptoms of Overexposure

Symptoms of overexposure to solvents will depend on the specific substance. Refer to the

MSDS of the chemical for this information.

General Procedures

1. Use solvents only in local exhaust hood or well ventilated areas.

2. Do not continue to work if you feel dizzy or sleepy. Have a co-worker secure your apparatus

(turn off heat, close containers, etc.) and escort you away from the area.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected

clothing.

2. If dizziness occurs from inhalation, get to fresh air.

3. In the event of a spill:

# Turn off all sources of flame or sparks. Keep area well ventilated.

# Small spills can be handled by using a solvent spill kit.

4. Use only an approved fire extinguisher to extinguish flames. Do not use water on liquid

fires. Pouring water on these fires may only spread the flames over a wider area.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.
DEECO Health and Safety Plan Page 53 January 2010

3.8 Oxidizing Agents

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Oxidizing agents can be irritating to skin, eyes, and the respiratory tract.

2. Most oxidizing agents are highly reactive, and may react violently with metals, as well as

other chemicals.

3. Oxidizers are corrosive and can cause burns on skin and eyes.

4. Oxidizers spontaneously evolve oxygen, and therefore may create a fire on explosion hazard

in some environments.

Symptoms of Overexposure

Symptoms of overexposure to solvents will depend on the specific substance. Refer to the

MSDS of the chemical for this information.

General Procedures

1. Do not mix with organic solvents.

2. Always store in unbreakable, inert containers.

3. Do not use cork or rubber stoppers.

4. Respiratory protection is required when handling chlorine or bromine gas.

5. Label containers of oxidizers with the date received, and the date the container was first

opened.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected

clothing.

2. In the event of a spill:

# Turn off all spark and open flame sources.

# Cover spill area with a bisulfite solution. Mix well and spray with water. Place

waste in container with water.

3. If a gas leak occurs, remove all sources of spark or flame. Place cylinder in an exhausted

enclosure or remove it to a safe outdoor area as soon as possible.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.

3.9 Asbestos Awareness

Asbestos is the name applied to six naturally occurring minerals that are mined from the earth.

Because it is so hard to destroy asbestos fibers, the body cannot break them down or remove them

once they are lodged in lung or body tissues. They remain in place where they can cause disease. 

There are three primary diseases associated with asbestos exposure:

Asbestosis 

Lung Cancer 

Mesothelioma 
DEECO Health and Safety Plan Page 54 January 2010

DEECO personnel may be exposed to asbestos while on a client's premises. The most common use

of asbestos at our client’s facilities is insulation on pipes and vessels. Asbestos boiler insulation

does not present a hazard unless the protective covering is cut or damaged in such a way that the

asbestos underneath is actually exposed to the air. The project manager/field team leader will ensure

that the client has identified or provided means to identify asbestos-containing equipment. 

If you do not know whether something is asbestos or not, assume that it is until it is verified

otherwise.

DO NOT DISTURB IT. 

Never...

Drill 

Hammer 

Cut 

Saw 

Break 

Damage 

Move 

Disturb 

...any asbestos-containing materials or suspected materials.

3.10 Benzene Awareness

Benzene is a volatile chemical formed from both natural processes and human activities. Natural

sources of benzene include emissions from volcanoes and forest fires. Benzene is also a natural part

of crude oil, gasoline, and cigarette smoke. Benzene is widely used in the United States, ranking in

the top 20 chemicals for production volume. It is primarily used as a solvent, as a starting material

for the production of other chemicals, and as a gasoline additive. Breathing benzene can cause

drowsiness, dizziness, and unconsciousness; long-term benzene exposure causes effects on the bone

marrow and can cause anemia and leukemia. The Occupational Safety and Health Administration

(OSHA) recognizes benzene as a hazardous material and imposes strict exposure limits in the

workplace. 

It is unlikely that DEECO personnel would be exposed to benzene on a client's premises at levels

above the OSHA permissible exposure limits (1 ppm TWA for 8 hour and 5 ppm STEL for 15

minutes). If the potential for benzene exposure exists, the project manager/field team leader will

ensure that the client has identified regulated areas where the permissible exposure limits could be

exceeded.

DEECO does not use benzene for any sample recovery procedures.

3.11 Hydrogen Sulfide Awareness

Hydrogen sulfide (H2S) is a colorless gas with a powerful nauseating smell of rotten eggs. The odor

is a poor warning property because hydrogen sulfide exposure quickly deadens the sense of smell.

The gas is heavier than air and may collect in low areas such as sewers, pits, tunnels or gullies. High

airborne levels of hydrogen sulfide (between 4.3 and 46.0 percent of gas by volume in the air) may

catch fire if there is a source of ignition. If the gas is burned, toxic products such as sulfur dioxide
DEECO Health and Safety Plan Page 55 January 2010

will be formed. Hydrogen sulfide is incompatible with oxidizing agents, such as nitric acid and

chlorine trifluoride, and may react violently or ignite spontaneously.

Hydrogen sulfide is extremely toxic. It may cause death instantaneously in high airborne

concentrations. Low levels may be extremely irritating to the lungs, nose, throat and eyes. 

Hydrogen sulfide can be detected by smell at levels as low as 0.13 parts hydrogen sulfide per million

parts air (ppm). Odor cannot be used as a warning because the gas can deaden the sense of smell

within 2 to 15 minutes in exposures of approximately 100 ppm. A single breath of hydrogen sulfide

at about 1000 ppm may paralyze the respiratory system and result in coma and death. Convulsions

may also occur. Prolonged exposure at about 250 ppm hydrogen sulfide may cause the lung tissue

to swell and fill up with water (pulmonary edema). 

This effect may occur after the exposed worker recovers from the irritant effects of the gas.

Exposures of 20 to 50 ppm hydrogen sulfide for one hour may cause inflammation of the cornea and

the delicate lining of the eye and eyelid (a condition called keratoconjunctivitis). Exposures for long

periods at 50 ppm may cause severe irritation of the nose, throat and lungs. Workers exposed to

lower concentrations of hydrogen sulfide may develop headaches, eye disorders and chronic

bronchitis. 

DEECO personal may be exposed to hydrogen en sulfide on a client's premises at levels above the

OSHA permissible exposure limits (20 ppm (ceiling) with the following exception: if no other

measurable exposure occurs during the 8-hour work shift, exposures may exceed 20 ppm, but not

more than 50 ppm (peak), for a single time period up to 10 minutes.). Small amounts of hydrogen

sulfide occur in crude petroleum but natural gas can contain up to 90%. By far the largest industrial

route to H2S occurs in petroleum refineries. Other sources of hydrogen sulfide include coke ovens,

paper mills (using the sulfate method), and tanneries. H2S arises from virtually anywhere where

elemental sulfur comes into contact with organic material, especially at high temperatures.

Should the potential exist for exposure to H2S, the project manager/field team leader will work with

the client to ensure that all personnel are provided with the following training;

1. Identification of the characteristics, sources, and hazards of Hydrogen Sulfide, 

2. Proper use of the Hydrogen Sulfide detection methods used on the site,

3. Recognition of, and proper response to, Hydrogen Sulfide warnings at the workplace,

4. Symptoms of Hydrogen Sulfide exposure,

5. Proper rescue techniques and first-aid procedures to be used in a Hydrogen Sulfide exposure,

6. Proper use and maintenance of personal protective equipment. Demonstrated proficiency in

using PPE should be required,

7. Worker awareness and understanding of workplace practices and maintenance procedures

to protect personnel from exposure to hydrogen sulfide,

8. Wind direction awareness and routes of egress,

9. Confined space and enclosed facility entry procedures.

10. Locations and use of safety equipment,

11. Locations of safe briefing areas,

12. Use and operation of all Hydrogen Sulfide monitoring systems, and

13. Emergency response procedures, corrective action, and shutdown procedures.
DEECO Health and Safety Plan Page 56 January 2010

At most client facilities where hydrogen sulfide exposure could occur, this training is required by

the client prior to entry.

3.12 Lead Awareness

Lead is a toxic metal that was used for many years in products found in and around our homes. Lead

also can be emitted into the air from motor vehicles and industrial sources, and lead can enter

drinking water from plumbing materials. Lead may cause a range of health effects, from behavioral

problems and learning disabilities, to seizures and death. Children six years old and under are most

at risk.

Most Common Sources of Lead Poisoning:

1. Deteriorating lead-based paint,

2. Lead contaminated dust, and

3. Lead contaminated residential soil 

DEECO personal may be exposed to lead hazards created by renovation, repair and painting (RRP)

activities at client facilities that disturb lead-based paint. The lead exposure limit is fifty micrograms

per cubic meter of air (50 ug/m3

) averaged over an 8-hour period. The project manager/field team

leader will ensure that the client has identified any areas where the potential for exposure to lead

exists and access these areas by DEECO employees will be prohibited.
DEECO Health and Safety Plan Page 57 January 2010

4.0 Hazard Communication Requirements

Introduction

The Occupational Safety and Health Administration's (OSHA) Hazard Communication Regulation

(29 CFR 1910.1200) requires that employees be informed of all hazardous chemicals located in their

workplace.

This program will describe how DEECO intends to protect the safety and health of our employees

who are exposed to hazardous chemicals in the workplace, and to comply with the provisions of 29

CFR 1910.1200.

Each supervisor will be held responsible for strict adherence to these policies and will closely

monitor all activities involving hazardous chemicals.

Each employee will carefully follow established work practices and promptly report observed or

potential problems to supervision.

There is no job at DEECO so vital or urgent as to justify the risk of employee overexposure to a

hazardous chemical. Ask when in doubt. Proceed with a job only after being satisfied that it is safe

for you to do so.

A list of all hazardous chemicals for each workplace has been made and is readily available, upon

request, to any employee, working on any shift. It is located in each tow vehicle, shop area, and wet

chemistry lab.

DEECO is responsible to ensure that the list of hazardous chemicals is kept current and that a current

MSDS for each hazardous chemical used is on hand. A chemical that is not shown on the current

list will not be ordered without prior coordination with the wet chemistry lab manager.

All containers of hazardous chemicals in each workplace will be conspicuously labeled with the

identity of the chemical, and the appropriate hazard warnings. If the chemical is a known or

suspected carcinogen, or it is known to affect a specific organ of the body, this information will also

be placed on the container label. The person having supervisory responsibility for the storage or use

or each hazardous chemical will ensure that such labels are not defaced and that they remain legible

at all times. The health and safety officer will ensure that an adequate supply of labels are on hand

and made available to the responsible supervisors.

When an outside contractor is used, it will be the responsibility of the project manager to advise the

contractor of any hazardous chemical to which their employees may be exposed and the appropriate

protective measures to be taken. This procedure also works conversely.

All employees exposed to any hazardous chemicals will complete an information and training

program which includes at least the subjects listed below. New employees must complete similar

instructions before initial exposure to any hazardous chemical in the workplace.
DEECO Health and Safety Plan Page 58 January 2010

Adequate training of all employees exposed to hazardous chemicals will be given by the Health and

Safety Officer or an approved training instructor and assisted as needed by the Hazard

Communication Program Monitor.

Employee information for this program will include:

1. The purpose and need for such a program, including the basic concept that gives every employee

the right to know about hazardous chemicals with which they work.

2. The location and availability of the written Hazard Communication Program, plus the list of

hazardous chemicals and their corresponding MSDS's.

3. The identity upon request, of any chemical to which the employee id exposed. In the case of a

trade secret chemical, the name on the MSDS will be provided.

Employee training shall include at least the following:

1. Methods and observations used to detect the presence or release of a hazardous chemical in the

work ares such as monitoring devices, appearance, or odor.

2. The physical and health hazards associated with each chemical, as specified in the MSDS.

3. Action that employees can take to protect their own safety and health, including specific

procedures that have been established for normal work practices, emergency procedures, and policies

on the use of personal protective equipment.

4. Details of the Hazard Communication Program, including an explanation of the labeling system

used on in-house containers of hazardous chemicals. Also, details of how employees can obtain and

use information contained in the MSDS.

It is the intent of DEECO management to protect the safety and health of each employee, our most

valuable and valued asset. By following correct procedures, no employee should experience and

harmful effects from working with chemicals in their workplace.

Client Responsibilities

Clients are required to inform DEECO personnel working on the premises of all hazards located in

the area. In addition to chemical hazards, the client should inform DEECO:

# Location of all emergency exits.

# Location of nearest medical facilities.

# Location of nearest emergency equipment (fire extinguishers, safety showers,

eyewashes, etc.)

The client should have available for DEECO personnel MSDSs on all chemicals located in the

area(s) where DEECO will be performing work.

The team leader should ensure that the above information is obtained before setting up equipment

to perform the work.
DEECO Health and Safety Plan Page 59 January 2010

DEECO Responsibilities

DEECO is required to inform its employees of all hazards that they may contact. MSDSs for each

chemical used by the Field Division are available in the central MSDS file located at the field office.

DEECO must also supply the client, upon request, information on the chemicals which DEECO

brings on the client's premises to perform field work. MSDSs are present prior to entering the

client's premises.

Written Program

The OSHA regulation requires that DEECO have a written Hazard Communication Program. The

written program for the Field Division is located in Appendix D of this Health and Safety Plan.

4.1 Material Safety Data Sheets

The manufactured or distributor of chemicals used by DEECO is required to supply DEECO with

a MSDS. Employees must be informed of the information on the MSDS prior to working with a

chemical.

A MSDS must exist for all hazardous chemicals. MSDSs for chemicals used on a client's site must

be available for review or photocopying by the client. A list of all chemicals brought on site by

DEECO should be supplied to the client. The client should be informed that a MSDS is available

for each chemical on that list.

Hazardous materials that require a MSDS are substances which may present a physical or health

hazard. A material presents a Physical Hazard if it is:

# Flammable

# Combustible

# Explosive

# Reactive

# Under Pressure

A material presents a Health Hazard if it is:

# Corrosive

# An Irritant

# A Sensitizer

# A Carcinogen

# Harmful to body organs, including skin, eyes, reproductive organs, liver, kidneys,

lungs, blood, or nervous system.

Each MSDS is required to provide the user with the following information:

Section I - Supplier Information. This section must include the manufacturer's name, address, and

an emergency telephone number. Also included in Section I is the name of the chemical as it appears

on the chemical label. Synonyms for the chemical name may also be given.
DEECO Health and Safety Plan Page 60 January 2010

Section II - Hazardous Ingredients Information. This section will list all the hazardous ingredients

of the chemical if they constitute 1% of the mixture or more. If the hazardous ingredient is a

carcinogen (capable of causing cancer), the ingredient will be listed if it constitutes 0.1% of the

mixture or more. Also listed for each ingredient will be the percentage that it makes up of the

mixture, and its current permissible exposure level (PEL).

Section III - Physical/Chemical Characteristics. This section will list characteristics such as boiling

point, vapor pressure, specific gravity, melting point, vapor density, evaporation rate, and solubility

in water. The substance's appearance and odor characteristics will also be given.

Section IV - Fire and Explosion Hazard Data. Included in this section will be the chemical's flash

point, flammability limits (upper and lower), the correct type of material to use to extinguish a fire,

any unusual fire and explosion hazards, and any special fire fighting procedures.

Section V - Reactivity Data. This section will list any conditions that should be avoided with this

chemical, whether or not the chemical is stable, substances the chemical is incompatible with, any

hazardous decomposition products or any hazardous polymerization that may occur.

Section VI - Health Hazard Data. Information included in this section will be possible routes of

exposure, signs and symptoms of overexposure (both acute and chromic exposures), medical

conditions that may be aggravated by exposure to this chemical, and emergency first aid.

Section VII - Precautions for Safe Handling. This section will list steps to be taken in the event of

a spill or release of the chemical, the proper waste disposal methods, and any precautions that should

be taken during handling and storage.

Section VIII - Control Measures. Included in this section will be the proper personal protective

equipment (respiratory protection, gloves, eye/face protection), the required ventilation system, and

other work practices that should be followed when using this chemical.

Section IX - Additional Information. This section will list any other pertinent information such as

transportation requirements or where to get other information regarding the chemical.

4.2 Chemical Labelling

All chemicals used in the field or at DEECO must be labelled. Chemical containers received from

the manufacturer are required to contain the chemical's name, hazard warnings, and the

manufacture's name and address. This manufacturer's label may not be defaced in any manner.

Beakers and other containers used by DEECO employees must also be clearly labelled with the

chemical name at all times.

Several chemical manufacturers place the NFPA (National Fire Protection Association) hazard label

on the bottle. This label identifies some of the hazardous properties of the chemical. 

Transfer containers used by more than one employee must be labelled. Chemical formulas must not

be used (for example, use "Acetone" instead of CH3COCH3

).
DEECO Health and Safety Plan Page 61 January 2010

4.3 Employee Exposure Monitoring

In order to ensure that field personnel are not overexposed to hazardous materials, the DEECO

Safety Officer may direct the Project Manager or Coordinator to perform employee exposure

monitoring.

Results from monitoring surveys will be forwarded to the department managers. The manager must

review the report with each employee in the department. This can be accomplished by reviewing

the report in a department meeting or circulating the report to all employees. Employees must sign

an Employee Notification Form which accompanies the report. The employees' signatures indicate

that the report was reviewed and understood by each employee. The decision to monitor employee

exposure will be made on a project-by-project basis by the DEECO S.O. and the Project Manager

or Coordinator.

The department managers must retain copies of all monitoring reports. These reports should be

reviewed with all new employees, or employees being reassigned to the area, before allowing the

employee to work in the area.

Employees may review past sampling reports that are representative of their exposure by contacting

their department manager, the Director of Personnel, or the DEECO S.O.

4.4 Employee Medical Surveillance

DEECO requires each employee to take a pre-employment physical. This physical establishes the

employee's physical condition before performing work at DEECO. In addition, DEECO field

employees will receive annual physicals based upon their job description and age.

Employees may receive additional medical evaluation if:

# Signs or symptoms associated with exposure to a hazardous chemical at DEECO

develop.

# Routine exposure monitoring indicate that employee exposure exceeds the

Permissible Exposure Level or Action Level for a given substance.

# A spill, leak or other event occurs which may have resulted in exposure to a

hazardous exposure.

These physicals will be provided during normal working hours (when possible) and at no cost to

employees. Copies of all medical evaluations will be forwarded to the Director of Personnel for

placement in the employee's confidential, personal file. Physical evaluations made under the above

conditions shall not reveal findings of diagnoses unrelated to the employee's occupational exposure.

Employees may at any time, review all medical information on file by contacting either the

department manager or the Director of Personnel.

4.5 Employee Access to Records

Employees may be asked to participate in chemical exposure monitoring. DEECO will maintain

records of employee medical surveillance, exposure monitoring, and occupational accidents or

injuries. As per OSHA regulations, this information may be reviewed by employees by requesting
DEECO Health and Safety Plan Page 62 January 2010

the information from the Area Supervisor, Manager or the Personnel Director. A copy of the OSHA

standard regarding access to exposure and medical records may be obtained from the DEECO S.O.

Responsibilities

The DEECO Safety Officer must ensure that:

# All employee exposure monitoring reports are reviewed by employees, and that

employees acknowledge the receipt of the reports by signing the report.

# Copies of the signed report are sent to the Personnel Director.

# Other information, such as MSDSs, ventilation records, etc. are maintained for at

least 30 years.

The Personnel Director must ensure that:

# Employee medical, exposure and accident/injury records are maintained for the

length of employment plus thirty (30) years.

# A response to any internal and external requests for medical or exposure records is

given within 15 working days.

The Department Managers must ensure that:

# Employees review and sign all Employee Exposure reports.

# Employees are advised of the right to access medical and exposure records annually

in a department safety meeting.
DEECO Health and Safety Plan Page 63 January 2010

5.0 Personal Protective Equipment

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

requirements for personal protective equipment, field personnel are to follow the procedures which

are more stringent. In all cases, all OSHA and/or EPA requirements are to be met. Field personnel

are not to use personal protective equipment for which they have not received adequate training in

their use and limitations.

Protective equipment, including personal protective equipment for eyes, face, head, and extremities,

protective clothing, respiratory devices, and protective shields and barriers, will be provided, used,

and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of

processes or environment, chemical hazards, radiological hazards, or mechanical irritants

encountered in a manner capable of causing injury or impairment in the function of any part of the

body through absorption, inhalation or physical contact.

Where employees provide their own protective equipment, DEECO will be responsible to assure its

adequacy, including proper maintenance, and sanitation of such equipment.

All personal protective equipment shall be of safe design and construction for the work to be

performed. The protective equipment, including personal protective equipment (PPE) will be

provided by DEECO at no cost to employees. DEECO will pay for replacement PPE, except when

the employee has lost or intentionally damaged the PPE.

5.1 Respiratory Protection

Detailed information regarding the use of specific respirators is located in the DEECO Field Division

Written Protection Program.

Use

Only employees that have been trained in the use of respiratory protection shall select or wear

respirators. Employees must:

# Be fit-tested and trained annually.

# Ensure that equipment is clean, available, and in good repair.

# Use equipment only as instructed.

# Receive medical clearance to wear a respirator.

# Not have beards, long side-burns, or other conditions that may preclude a good faceto-facepiece seal.

# Ensure that the proper respirator cartridge or canister is used for a particular

contaminant. All cartridges are marked and color-coded.

When donning the respirator:

# Place mask on face with chin in chin-cup.

# Attach lower straps around neck.

# Place top straps on crown of head, above ears.

# Tighten all straps.
DEECO Health and Safety Plan Page 64 January 2010

Each time the respirator is conned, positive and negative pressure fit-checks must be performed.

Positive Pressure Fit-Checks:

# Place the palm of hand over the exhalation valve.

# Exhale gently. The mask should lift off the face without allowing the air to escape.

Negative Pressure Fit-Checks:

# Cover the inlets of the cartridges with hands.

# Inhale gently. The mask should collapse around the face without letting air in around

the face-to- respirator seal.

Selection

Respirators provide specific Protection Factors based on the type to respirator and the cartridge or

canister in use. The Protection Factor is defined as the concentration of an air contaminant outside

the mask divided by the concentration of that some contaminant inside the mask. For example, the

half-mask respirator with HEPA (High Efficiency Particulate Absolute) filter cartridge has a

Protection Factor of 10. This indicates that if worn in an area with a concentration of 0.05 mg/m3

of airborne lead, the employee would actually be exposed to 0.005 mg/m3 of lead.

Employees should select the type of respirator and cartridge based on the decision criteria located

in the DEECO Respiratory Protection written program.

Inspection

Employees must inspect each respirator prior to donning. Straps, inhalation and exhalation valves,

cartridge gaskets, and facepiece should be inspected to ensure all parts are present, clean and in good

condition.

Decontamination

Respirator should be cleaned after each use. Remove cartridges and place them in a plastic bag.

Wash respirator with warm, soapy water. Rinse the respirator thoroughly since soap can be a skin

irritant. Allow respirator to air dry. Place in plastic bag when dry and store in dry location away

from excessive heat. Do not place anything on top of respirator since this may distort the facepiece.

Breathing Air Quality and Use

When DEECO employees are required to use atmosphere-supplying respirators (supplied-air and

SCBA), DEECO will ensure that compressed air, compressed oxygen, liquid air, and liquid oxygen

used for respiration accords with the following specifications:

1. Compressed and liquid oxygen shall meet the United States Pharmacopoeia requirements for

medical or breathing oxygen;

2. Compressed breathing air shall meet at least the requirements for Grade D breathing air

described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-

1989, to include and oxygen content (v/v) of 19.5-23.5%, a hydrocarbon (condensed) content

of 5 milligrams per cubic meter of air or less, a carbon monoxide (CO) content of 10 ppm

or less; a carbon dioxide content of 1,000 ppm or less; and lack of noticeable odor.
DEECO Health and Safety Plan Page 65 January 2010

DEECO will ensure that compressed oxygen is not used in atmosphere-supplying respirators that

have previously used compressed air and ensure that oxygen concentrations greater than 23.5% are

used only in equipment designed for oxygen service or distribution.

DEECO will ensure that cylinders used to supply breathing air to respirators meet the following

requirements:

1. Cylinders are tested and maintained as prescribed in the Shipping Container Specification

Regulations of the Department of Transportation (49 CFR part 173 and part 178);

2. Cylinders of purchased breathing air have a certificate of analysis from the supplier that the

breathing air meets the requirements for Grade D breathing air; and

3. The moisture content in the cylinder does not exceed a dew point of -50 deg.F (-45.6 deg.C)

at 1 atmosphere pressure.

DEECO will ensure that compressors used to supply breathing air to respirators are constructed and

situated so as to:

1. Prevent entry of contaminated air into the air-supply system;

2. Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F

(5.56 deg.C) below the ambient temperature;

3. Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air

quality. Sorbent beds and filters shall be maintained and replaced or refurbished periodically

following the manufacturer's instructions;

4. Have a tag containing the most recent change date and the signature of the person authorized

by the employer to perform the change. The tag shall be maintained at the compressor.

For compressors that are not oil-lubricated, the DEECO will ensure that carbon monoxide levels in

the breathing air do not exceed 10 ppm.

For oil-lubricated compressors, the DEECO will use a high-temperature or carbon monoxide alarm,

or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply

shall be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from

exceeding 10 ppm.

The DEECO will ensure that breathing air couplings are incompatible with outlets for non-respirable

work site air or other gas systems. No asphyxiating substance shall be introduced into breathing air

lines.

DEECO will use breathing gas containers marked in accordance with the NIOSH respirator

certification standard, 42 CFR part 84.
DEECO Health and Safety Plan Page 66 January 2010

5.2 Gloves

Use & Selection

Gloves should be worn when there is a potential for skin contact, such as pouring chemicals,

washing glassware with solvents, collecting samples, etc. Different gloves protect against different

chemicals. The glove compatibility chart below should be consulted when selecting gloves.

Inspection

Employees must check the gloves before donning by:

# Inspecting for cracks, holes, or tears.

# Performing a leak test by grasping the cuff of the glove quickly such that air is

trapped inside the glove. Squeeze the glove to ensure that air cannot escape. If a

glove has any hole, crack, or tear, or has evidence of degradation to the material,

discard the glove.

Employees must ensure that an ample supply of the proper gloves are always available in the field.

Decontamination

Employees should rinse gloves with water before removing. Gloves should be turned inside-out

during removal. Contaminated gloves are to be discarded.

Glove Selection Chart

Chemical(s) Glove Type

Solvents Nitrile (Sol-Vex)

-Chlorinated PVA

Acids, Bases Nitrile (Sol-Vex)

Neoprene (Stanzoil)

PVC Coated

Sample Collection Disposible Latex

5.3 Protective Eyewear

Use & Selection

Chemical and physical hazards in the field have the potential to produce injuries to the eye and face.

These injuries could seriously impair or destroy vision, or permanently destroy facial skin. DEECO

provides eye and face protective equipment to employees at no cost. 

It is the responsibility of the Field Coordinator and Field Employees to ensure that proper eye and

face protection is available and worn in the work area. Contact lenses may not be worn in areas

requiring safety glasses.
DEECO Health and Safety Plan Page 67 January 2010

Eyewear Hazards

Safety Glasses To be worn at all times on the work site or in designated "Eye

Protection Required" areas.

Safety Goggles To be worn whenever there is a potential of a chemical splash

(e.g. handling or pouring solvents.)

Face Shields To be worn when handling or pouring acids, bases, or other

corrosive chemicals; when there is a potential of flying debris

from drilling, cutting or grinding materials with power tools.

Inspection

All safety glasses must meet the American National Standards Institute (ANSI) Standard Z87.1.

Safety glasses are required to have "Z87.1" stamped on the inside of the frame, or etched on the

lenses. DEECO will provide prescription safety glasses to those employees that require corrective

lenses.

Safety glasses, goggles, or face shields that show visible signs of deterioration or damage should be

repaired or discarded. If a damaged item is to be repaired, it should be placed in a plastic bag,

sealed, and labeled "DAMAGED EQUIPMENT: FOR REPAIR".

Decontamination

All safety eyewear should be thoroughly cleaned with soap and water after each use in a

contaminated, or potentially contaminated, area.

5.4 Protective Clothing

In many work situations it may be necessary for field personnel to wear full body protective clothing.

The Project Manager or Coordinator should identify the types of protective clothing that may be

necessary for a particular project, and ensure that the equipment is available at the work site. Brief

descriptions of the various protective clothing materials are given below. In most situations, only

Tyvek or Saranex clothing will be necessary.

Standard Tyvek (non-porous)

Non-woven, olefin fiber fabric. Suitable for protection against most dusts, mists, and fumes.

Fabric melts at temperatures above 270 EF. Should not be used to protect against solvent

vapors or acid gases/fumes.

Saranex Tyvek

Standard Tyvek which has one side coated with saranex plastic. This gives the clothing a

high level of resistance to most hazardous chemicals, including PCBs. Should not be used

in temperatures above 270 EF.
DEECO Health and Safety Plan Page 68 January 2010

Polyethylene Coated Tyvek

Standard Tyvek which has one side coated with polyethylene. This gives the clothing a high

level of resistance to most hazardous chemicals, including PCBs. More resistent to moisture,

and will protect individuals against chemical spills and splashes better than the Saranex

Tyvek. Should not be used in temperatures above 270 EF.

Protective clothing is available in other materials, such as polyvinyl chloride, neoprene, Viton, and

butyl rubber. These materials protect against a higher degree of hazard than Field personnel would

be expected to encounter. If the Project Manager or Coordinator feels that additional protection is

required for a specific project, he/she should discuss clothing options with the S.O.

5.5 OSHA Levels of Protection

Use & Selection

Employees should select the level of personal protective equipment required for each individual

work site based on the current EPA guidelines below. Employees are not to perform tasks in the

work area if the proper personal protective equipment is not available or in good working condition.

At a minimum, employees must wear safety glasses and safety shoes/boots at all work sites. DEECO

employees will not enter areas requiring Level A or Level B protection. All employees will be

trained on the proper use of protection equipment for Level C and Level D protection.

Levels of Protection

Level A - Highest level of respiratory, skin and eye protection is needed. Criteria include:

# High concentration of vapors, gases or particulates.

# High potential for splash, immersion or potential exposure to highly toxic

materials.

# Confined or poorly-ventilated areas.

Equipment:

# Supplied air respirator (pressure-demand SCBA or airline respirator with

escape bottle)

# Fully encapsulating chemical resistent suit

# Inner gloves, chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes coveralls, long cotton underwear, hard hat, disposable gloves and boot

covers, cooling unit, 2-way radios.

Level B - Highest level of respiratory protection, lesser level of skin protection. Criteria include:

# Atmospheres immediately dangerous to life and health (IDLH)

# Oxygen deficient atmosphere (<20%).

# Low potential for splash, immersion or potential exposure to highly toxic

materials.
DEECO Health and Safety Plan Page 69 January 2010

Equipment:

# Supplied air respirator (pressure-demand SCBA or airline respirator with

escape bottle)

# Chemical resistent clothing

# Outer gloves, chemical resistent

# Inner gloves, chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes long cotton underwear, hard hat, disposable gloves and boot covers,

cooling unit, 2-way radios.

Level C - Conditions allow the use of air-purifying respirators. Criteria include:

# Oxygen concentrations not less than 20%.

# Concentrations of identified contaminants will be reduced by the respirator

below the contaminants TLV, and the concentration is within the service limit

of the canister/cartridge.

# Concentrations of contaminants to not exceed IDLH levels.

# Low potential for splash, immersion or potential exposure to highly toxic

materials.

# FID or PID measurements show concentrations only a few ppms above

background.

Equipment:

# Air-purifying, full-face respirator with appropriate canister or cartridges 

# Chemical resistent clothing

# Outer gloves. Chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes long cotton underwear, hard hat, disposable gloves and boot covers,

escape mask, hard hat, 2-way radios.

Level D - No respiratory or skin hazards exist. Criteria include:

# No contaminants present.

# No potential for splash, immersion or potential exposure to any chemicals.

Equipment:

# Coveralls or work clothing

# Safety shoes/boots

# Safety glasses

# Hard hat

Optional Equipment includes gloves, face shield.
DEECO Health and Safety Plan Page 70 January 2010

5.5 Training for the Use Personal Protective Equipment

DEECO will provide training to each employee who is required to use PPE. Each such employee

will be trained to know when PPE is necessary, what PPE is necessary, how to properly don, doff,

adjust, and wear PPE, the limitations of the PPE, and the proper care, maintenance, useful life and

disposal of the PPE.

Each affected employee will be required to demonstrate an understanding of the training and the

ability to use PPE properly, before being allowed to perform work requiring the use of PPE.

When DEECO has reason to believe that any affected employee who has already been trained does

not have the understanding and skill required, DEECO will retrain each such employee.

Circumstances where retraining is required include, but are not limited to, situations where changes

in the workplace render previous training obsolete, changes in the types of PPE to be used render

previous training obsolete, or inadequacies in an affected employee's knowledge or use of assigned

PPE indicate that the employee has not retained the requisite understanding or skill.

DEECO will verify that each affected employee has received and understood the required training

through a written certification that contains the name of each employee trained, the date(s) of

training, and that identifies the subject of the certification.
 

Holcim (US) Inc. 

122 West Carpenter Freeway

Suite 485 

Irving, Texas 75039 

Phone 214-596-9760

 800-326-1821

Fax 214-596-0767

www.holcim.com/us 

March 30, 2010 

Mr. Keith Barnett 

US EPA Mailroom (D243-02) 

109 T.W. Alexander Drive 

Research Triangle Park, NC 27711 

RE: Holcim Submittal to the EPA Section 114 for the Collection of HCL Emission 

Data 

Dear Mr. Barnett: 

On February 3, 2010, the Environmental Protection Agency (EPA) requested 

information from Holcim (US), Inc., pursuant to Section 114 of the Clean Air Act 

(CAA). As part of this request Holcim was required to test the facilities shown in 

Table 1 for HCL emissions using EPA Method 321 of Appendix A, 40 CFR Part 

63. 

Table 1. EPA HCL 114 Request 

Facility City, State 

Holcim (US), Inc. Ada, Oklahoma 

Holcim (US), Inc. Theodore, Alabama 

Holcim (US), Inc. Portland, Colorado 

Holcim (US), Inc. Devils Slide, Utah 

Holcim (US), Inc. Dundee, Michigan 

Holcim (US), Inc. Mason City, Iowa 

EPA allowed for other kilns to be substituted for kilns listed in Table 1 if those 

kilns were currently shut down or for some reason could not be tested in the time 

frame specified. Table 2 provides a list of the Holcim facilities that were tested 

as part of this 114 request. 
Table 2. Holcim HCL Testing Status 

Facility City, State Status 

Holcim (US), Inc. Ada, Oklahoma Completed 

Holcim (US), Inc. Devils Slide, Utah Completed 

Holcim (US), Inc. Ste. Genevieve Completed 

Holcim (US), Inc. Portland, Colorado 29-Mar 

Holcim (US), Inc. Catskill, New York TBA April 

Holcim (US), Inc. Midlothian, Texas TBA April 

Please find enclosed a copy of a site specific test protocol and the HCl findings 

for the Ada, Devils Slide, and Saint Genevieve Plants. The Portland, Colorado 

facility is being tested the week of March 29th and upon completion its findings 

will be submitted to EPA. At the time of the 114, the Theodore plant was down 

and the Dundee and Mason City plants were shutdown. Therefore, Holcim 

substituted the Catskill and Midlothian plants. Catskill and Midlothian were down 

most of February and March; however, these plants will be tested during the 

month of April. While this is beyond the March 31st date, Holcim will continue to 

test into April and HCl emission data for Catskill and Midlothian will be submitted 

to EPA upon completion. Currently Catskill is scheduled for the week of April 9th 

and Midlothian for the week of April 26. 

If you have any questions or comments please feel free to contact me at 972-

268-1139. 

Sincerely, 

HOLCIM (US), INC. 

Hector Ybanez 

Corporate Manager, Environmental 

 
DEECO Inc.

3404 Lake Woodard Road

Raleigh, NC 27604

(919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com

Site-Specific Test Plan

U.S. EPA Information Collection Request

for

Hydrogen Chloride Emissions

from

Portland Cement Manufacturing Facilities

Holcim (US) Inc. - Devils Slide Plant

6055 East Croydon Road

Morgan, Utah 84050

Submitted By:

DEECO, INC.

3404 Lake Woodard Road

Raleigh, NC 27603

February 20, 2010

Proposed Test Date: February 24-25, 2010
TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Test Program Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.0 SOURCE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3.0 TEST PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.1 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.2 Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.3 PROCESS PERFORMANCE INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3.4 Test Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

4.0 SAMPLING LOCATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

4.1 Flue Gas Sampling Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

5.0 SAMPLING AND ANALYTICAL PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.1 Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.2 Sampling Point Determination - EPA Method 1 . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 . . . . . . . . . . . . . 11

5.4 Outlet Flue Gas Composition - EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . 11

5.5 Flue Gas Moisture Content - EPA Method 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

5.6.1 Test Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

5.6.2 Conditioning and Operational Test Periods . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.3 Test Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.4 Test Procedures for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.4 Calibration Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

5.6.5 Test Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

5.6.6 Data Acquisition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

5.7 Test Procedures for EPA Method 321 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

6.0 QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1 QC PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1.1 Manual Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1.2 Manual Sampling Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1.3 Manual Sampling Quality Control Procedures . . . . . . . . . . . . . . . . . . . . 23

7.0 REPORTING AND DATA REDUCTION REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . 26

Format . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

7.2 Data Reduction and Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
TABLE OF CONTENTS (continuerd)

Section Page

8.0 PLANT ENTRY AND SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

8.1 Safety Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

8.2 Safety Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

8.3 Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE . . . . . . . . . . . . . . . . . . . . . 29

9.1 Test Site Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

9.2 Test Preparations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

9.3 Test Personnel Responsibilities and Detailed Schedule . . . . . . . . . . . . . . . . . . . 29

LIST OF TABLES

Table Page

TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS . . . . . . 6

TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE . . . . . . . . . . . . . 8

TABLE 6.1 SUMMARY QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLORIDE

EMISSION TEST RESULTS, HOLCIM (US) DEVILS SLIDE FACILITY, RAW

MILL OFF CONDITION; FEBRUARY 25, 2010 . . . . . . . . . . . . . . . . . . . . . . . 27

LIST OF FIGURES

Figure Page

Figure 1.1 Organization for Holcim (US) Inc. Devils Slide Facility HCl ICR Test Program

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Figure 4.1 Schematic of the Main Kiln/Raw Mill Stack sampling location . . . . . . . . . . . . . . . . 10

Figure 6.1 Example field data sheet for EPA Methods 2 and 4 . . . . . . . . . . . . . . . . . . . . . . . . . 19

Figure 6.2 Example field data sheet for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
HCl ICR Site-Specific Test Protocol Page: 1

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

1.0 INTRODUCTION

1.1 Summary of Test Program

The U.S. Environmental Protection Agency (EPA), Office of Air Quality Planning and

Standards (OAQPS) has issued an Information Collection Request (ICR) to Holcim (US), Inc

(Holcim). Under the authority of Section 114 of the Clean Air Act (CAA). The EPA is requesting

information on hydrogen chloride (HCl) emissions from nonhazardous waste-burning kilns at

Portland cement manufacturing facilities. This request is in response to comments from Portland

cement industry members and its trade association to EPA’s proposal to amend the national emission

standards for hazardous air pollutants for Portland cement manufacturing (74 FR 21136 (May 6,

2009)).

Holcim has retained DEECO Inc. (DEECO) to conduct the required emissions testing.

Testing for HCl will be conducted in accordance with EPA Method 321 - Measurement of Gaseous

Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared (FTIR)

Spectroscopy. 

The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and

26A) may have positive biases due to chloride salts (such as ammonium chloride) that, when

collected in the sampling train, for chloride ions (Cl-

) that is indistinguishable from the Cl- ion

formed upon collection of HCl. In addition, a negative bias may also exist due to condensation

and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has

decided that the FTIR measurement by EPA Method 321 is the preferred technique for determining

the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement

manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/portland.pdf).

The Holcim facility located east Morgan, Utah in Morgan County (designated as the Devils

Slide plant with the physical address of 6055 East Croydon Road, Morgan, Utah 84050) has been

one of the Portland cement manufacturing facilities selected as part of the ICR

HCl emission tests will be conducted at the main kiln/raw mill stack during two conditions;

raw mill on (Mill On) and raw mill off (Mill Off). 

Testing is anticipated to be conducted February 24-25, 2010.

1.2 Test Program Organization

Figure 1.1 presents the test program organization, major lines of communication, and names

and phone numbers of responsible individuals.
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EPA OAQPS, Sector Policies and

Programs Division

Peter Tsirigotis

Research Triangle Institute

Contract EP -D-06-118

EPA Sector Policies and

Programs Division

Keith Barnett

(919)541-5605

Barnett.Keitht@epa.gov

Holcim (US), Inc.

Corporate Contacts

Ruksana Mirza

or 

Hector Ybanez

Corporate Manager,

Environmental

(214) 524 - 2814

Hector.Ybanez@holcim.com

Holcim (US), Inc.

Environmental Contact

Timothy Schlosser

(734)529-4118

Timothy.Schlosser@holcim.com

EPA report data

contact

Ron Meyers 

(919) 541-5407

myers.ron@epa.gov

or 

Barrett Parker 

(919) 541-5635

parker.barrett@epa.gov

Holcim (US) Inc.

Devils Slide Plant

Mr. Kevin Ovard

(801) 829-2122

Kevin.OVARD@holcim.com

EPA Test Method contact

Peter Westlin

(919) 541-1058

westlin.peter@epa.gov

or

Gary McAllister 

(919) 541-1062

mcalister.gary@epa.gov

DEECO Project Manager

Scott Steinsberger

(919)250-0285

deeco@deeco.com

DEECO Field Team

Figure 1.1 Organization for Holcim (US) Inc. Saint Genevieve Facility HCl ICR Test Program
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2.0 SOURCE DESCRIPTION

2.1 Process Description

The Devils Slide plant operation includes an on-site quarry, raw material storage, crushing

and milling, solid fuel (coal and petroleum coke) storage and milling, liquid fuel storage, one

preheater/precalciner cement kiln system, product milling, product storage, and loading and

unloading systems.

Cement manufacturing involves chemical and physical processing of large quantities of raw

materials. The raw materials used include sources of calcium, silica, alumina and iron. These are

the components necessary for the manufacture of the cement chemicals dicalcium silicate, tricalcium

silicate, tricalcium aluminate, and tetra-calcium aluminoferrite. The raw feed is prepared for use in

the kiln system by sizing, grinding and blending the various raw materials to produce the necessary

mix for quality production. The prepared raw feed is introduced to the kiln system where it is

physically and chemically transformed into clinker, the intermediate product of Portland cement.

In the kiln system, the raw materials are exposed to temperatures reaching up to 3,500EF through a

countercurrent process in the kiln and a co-current process in the preheater. The raw materials are

heated to 2,650EF, the temperature required to produce quality clinker. Both on-site and off-site

sources supply raw materials for cement kiln feed at the Ste. Genevieve plant. Quarry resources

include limestone and shale deposits that will comprise part of the raw material blend to become

clinker, the principal product. Materials received from off-site may include limestone, iron ore, clay,

bottom ash, fly ash, bauxite, diaspore, gypsum and other materials as necessary. An important

source of raw materials is nonhazardous waste materials from other industries that have the proper

chemical and physical properties to be used as a raw material source. The Ste. Genevieve plant is

designed for these types of materials as sources of calcium, silica, alumina and iron. Preparation of

raw materials, depending on its source and physical properties, involves primary and secondary

crushing, and screening, blending and grinding in the raw mills prior to entrance into the preheater

tower of the cement kiln system.

Holcim uses coal and petroleum coke as the primary fuels for the cement manufacturing

process at the Devils Slide plant. Holcim uses coal mills to prepare raw coal/coke for firing in the

precalciner and the kiln. Solid fuels are received at the facility by truck and rail. Liquid oils and

similar non-hazardous materials are used as a secondary fuel in critical situations such as start-up

and back-up. The facility’s equipment design also allows Holcim to beneficially use many other

sources of energy bearing, non-hazardous waste materials as supplemental fuel, such as whole or

shredded tires, when available. The preheater/precalciner pyroprocess is a state-of-the-art design that

features five-stage cyclone-type preheater tower, low-NOx precalciner, and a rotary kiln. The

preheater/precalciner portion of the system is located in a tall tower adjacent to the kiln. The lowNOx precalciner will be located at the base of the tower. The precalciner allows the burning fuel to

be thoroughly mixed with the kiln feed. Excess heated air from the clinker cooler (tertiary air) will

provide combustion air for the precalciner. Preheater/precalciner kilns feature greater thermal

efficiency as compared to long dry or long wet kilns. This results in significantly lower emissions

and decreased fuel consumption per ton of clinker produced. To increase energy efficiency even

further, hot exhaust gases from the preheater tower are utilized to dry kiln feed in the raw mills and

fuel in the coal mill.
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2.2 Control Equipment Description

Airflow from the raw mill, akali bypass, kiln, and coal mill are directed through a common

duct to fabric filter baghouses
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3.0 TEST PROGRAM

3.1 Objectives

Testing for HCl will be conducted in accordance with EPA Method 321 - Measurement of

Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared

(FTIR) Spectroscopy. 

The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and

26A) may have positive biases due to chloride salts (such as ammonium chloride) that, when

collected in the sampling train, for chloride ions (Cl-

) that is indistinguishable from the Cl- ion

formed upon collection of HCl. In addition, a negative bias may also exist due to condensation

and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has

decided that the FTIR measurement by EPA Method 321 is the preferred technique for determining

the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement

manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/portland.pdf).

The specific objectives in order of priority are:

C Measure the emissions of HCl (EPA Method 321) from the Cement Kiln/Raw Mill Stack

during two conditions; raw mill on (Mill On) and both raw mill off (Mill Off), and

C Concurrent with the HCl measurements, measure the Cement Kiln/Raw Mill Stack

volumetric flow rate (EPA Methods 1 and 2), the Cement Kiln/Raw Mill Stack oxygen and

carbon dioxide content (EPA Method3A), and the Cement Kiln/Raw Mill Stack moisture

content.

Relevant process information will be collected by plant personnel in conjunction with the

testing program. The raw process data will be presented as collected in the appendices of the final

report.

3.2 Test Matrix

Table 3.1 presents the sampling and analytical matrix.
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TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS

Test

Parameter

Sampling

Method Sample Type

Sampling

Frequency Analytical Method

Measurement

Technique

Volumetric

Flow Rate

EPA Methods

1 and 2

Traverse points;

thermocouple

and Pitot tube

Concurrent

with each

Method 321

test

EPA Method 2

(40 CFR 60, App A)

Thermocouple

readout and 

manometer

Oxygen and 

Carbon

Dioxide

EPA Method

3A

Extractive

instrumental

sample

Concurrent

with each 

Method 321

test

EPA Method 3A

(40 CFR 60, App A)

Paramagnetic

for O2 and

NDIR for CO2

Moisture EPA Method

4

Traverse points;

Condensation

Concurrent

with each 

Method 321

test

EPA Method 4

(40 CFR 60, App A) Gravimetric

Hydrogen

Chloride

EPA Method

321

Extractive

instrumental

sample

Three 60-

minute

test runs per

condition

EPA Method 321

(40 CFR 63, App A)

Fourier

Transform

Infrared

(FTIR)

spectrometry 
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3.3 PROCESS PERFORMANCE INFORMATION

Plant personnel in conjunction with the testing program will collect process information. The

raw process data will be presented as collected in the appendices of the final report.

3.4 Test Coordination

Mr. Kevin Ovard, the Holcim facility contact, will serve as the test coordinator. He will be

responsible for:

1. Scheduling the start of all testing;

2. Principal contact with the agency officials concerning the tests;

3. Principal contact with DEECO concerning the tests;

4. Recording the process data during the testing; and 

5. Providing copies of any field test data to the agency.

A tentative test schedule is shown in table 3.2.
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TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE

Sampling Location Parameter(s)

Measured

Sampling

Method

Number of Runs

and Duration

Length of

Day(s)

Day 1 - February 23, 2010 Arrive on-site and set up test equipment 8 hours

Days 2 & 3 - February 24-25, 2010

Kiln Stack Flue Gas Flowrate EPA Methods 1, 2, 4 Three 60-minute

runs per condition

(Mill On and Mill

Off)

10 hours

O2/CO2 EPA Method 3A

HCl EPA Method 321

Day 4 - February 26, 2010 Contingency Day
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4.0 SAMPLING LOCATIONS

4.1 Flue Gas Sampling Location

The kiln/raw mill stack is a vertically-oriented circular stack with an inside diameter of

approximately 134.5". The stack gas sampling ports are located approximately 100' (approximately

8.9 duct diameters) above the closest disturbance and approximately 25.5' (approximately 2.01 duct

diameters) from the stack outlet. The sampling location meets the minimum specifications for

selection of a measurement site as outlined in EPA Method 1.

A schematic of the Main Kiln/Raw Mill Stack sampling location is shown in Figure 4.1

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5.0 SAMPLING AND ANALYTICAL PROCEDURES

5.1 Test Methods

This section contains a brief description of the sampling and analytical procedures for each

method that will be employed during the test program. All equipment, procedures, and quality

assurance measures necessary for completion of the test program will meet or exceed the

specifications of the appropriate methods. Any deviations from the methods to ensure quality

representativeness of the results are also discussed.

5.2 Sampling Point Determination - EPA Method 1

The number and location of the sampling or traverse points will be determined according to

the procedures outlined in EPA Method 1. The sample location has already been confirmed to meet

EPA Method 1 based on previous source tests. All points will be at least 1.0 inches from the stack

wall, per Method 1. For the main kiln stack, a total of 12 velocity/isokinetic traverse points will be

used, with six points on each of the two 90o axes

5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2

The flue gas velocity and volumetric flow rate will be determined according to the procedures

outlined in EPA Method 2. Velocity measurements will be made using type S pitot tubes conforming

to the calibration specifications outlined in EPA Method 2, Section 10.1. Each Type-S pitot tube,

calibrated according to these standards, will have an assigned coefficient. Differential pressures will

be measured with Magnehelic gauges of appropriate range or with fluid manometers. Effluent gas

temperatures will be measured with chromel-alumel thermocouples equipped with digital readouts.

5.4 Outlet Flue Gas Composition - EPA Method 3A

Outlet flue gas analysis for oxygen (O2

) and carbon dioxide (CO2) concentrations, and the

calculation of percent excess air and flue gas dry molecular weight will be performed in accordance

with EPA Method 3A. Refer to Section 5.6 for more information

5.5 Flue Gas Moisture Content - EPA Method 4

The flue gas moisture content will be determined in conjunction with each sampling run and

according to the sampling and analytical procedures outlined in EPA Method 4. The impingers will

be connected in series, and contained in an ice bath in order to assure condensation of the moisture

in the flue gas stream. Any moisture that is not condensed in the impingers is captured in the silica

gel, therefore all moisture can be weighed and entered into moisture content calculations.
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5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321

A CEM system will be used to determine oxygen and carbon dioxide concentrations and

hydrogen chloride concentrations on the Main Kiln/Raw Mill stack. The procedures used in meeting

these requirements are detailed below.

5.6.1 Test Equipment Description

The instrumentation and all sampling and analytical procedures that will be used by DEECO

for the HCl ICR testing will conform with the requirements of EPA Test Methods 3A and 321 using

FTIR.

For HCl, the extractive system requires that the effluent gas sample be filtered and maintained

at a minimum of 356°F (180°C) prior to being delivered to the FTIR sample cell. The FTIR sample

cell will also be maintained at 356°F. The gas sample will be drawn through the extractive system

and the FTIR cell using a heated sample pump. The extractive system will be equipped with a glass

lined probe also heated to a minimum of 356°F. The probe will be of sufficient length to reach a

minimum of three traverse points at 17, 50, and 83 percent of the duct diameter or 0.4, 1.2, and 2.0

meters from the stack or duct wall, which ever is less. All components of the sampling system which

contact the sample will be either of glass, stainless steel, or Teflon

The extracted gas sample exiting the heated sample pump will be conditioned to remove

moisture with an ice water-cooled condenser. A gas distribution manifold will be used to deliver a

representative sample of flue gas to oxygen and carbon dioxide analyzers.

Fourier Transform Infrared (FTIR) spectroscopy for Hydrogen Chloride - FTIR spectroscopy

measures vapor phase organic or inorganic compounds which absorb energy in the mid-infrared

spectral region, about 400 to 4000 cm-1 (25 to 2.5 μm). Continuous measurement is made by

matching sample absorbance bands with bands in reference spectra, and comparing sample band

intensities with reference band intensities.

The principle limitation to FTIR spectroscopy are the presence of interfering compounds that

also absorb energy in the mid-infrared spectral region. In a cement kiln stack gas matrix, water vapor

(H2O) and carbon dioxide (CO2

) are the primary interferents that must be incorporated into the

identification and quantitation method.

By choosing the proper analytical region(s) for the HCl spectra, the effect of the interfering

compounds can be minimized. The analytical regions will be selected based on examination of the

actual stack gas matrix. (It should be noted that the analytical region provided as an example in EPA

Method 321 (2679-2840 cm-1) does not correspond with the entire analytical region for HCl (2600-

3100 cm-1). The example cited in Method 321 appears to have been copied from the formaldehyde

analytical region used as an example in Method 318.)

The FTIR software performs the computation for a single compound by subtracting all the

other compounds (interferants and target) from the absorbance spectra and quantifies the single

compound based on the remain absorbance. The FTIR software provides a Standard Error

Calculation (SEC) value that is an indication of how well the identification and quantitation has been

performed. A high SEC indicates that other interferants have not been accounted for in the analysis
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method, and a low SEC is indicative of greater confidence mesurement. Typically, if the reported

SEC is greater than half the reported concentration then the results is suspect. 

A MIDAC I-Series FTIR will be used to determine HCl concentrations according to EPA

Method 321. Infrared absorption spectroscopy is performed by directing an infrared beam through

a sample to a detector. The frequency-dependent infrared absorbance of the sample is measured by

comparing this detector signal (single beam spectrum) to a signal obtained without a sample in the

beam path (background). Most molecules absorb infrared radiation and the absorbance occurs in a

characteristic and reproducible pattern. The infrared spectrum measures fundamental molecular

properties and a compound can be identified from its infrared spectrum alone. Within constraints,

there is a linear relationship between infrared absorption and compound concentration. If this

frequency dependent relationship (absorptivity) is known (measured), it can be used to determine

compound concentration in a sample mixture.

Absorptivity is measured by preparing, in the laboratory, standard samples of compounds at

known concentrations and measuring the FTIR "reference spectra" of these standard samples. These

"reference spectra" are then used in sample analysis: (1) compounds are detected by matching sample

absorbance bands with bands in reference spectra, and (2) concentrations are measured by comparing

sample band intensities with reference band intensities.

Reference spectra for hydrogen chloride and sulfur hexafluoride will be generated from

commercially-available calibration gas cylinders. The EPA reference spectra available from the

EPA’s Emission Measurement Center are not representative of the concentrations (at 189.5 ppmmeters and 497.3 ppm-meters) being measured. HCl reference spectra at 2 ppm and 5 ppm (16.3

ppm-meters and 40.8 ppm-meters) will be used. Secondly, higher resolution spectra, compared to

the EPA reference spectra, will be necessary due to the low HCl concentrations that are expected and

the high moisture levels (up to 35%) that will be encountered. Thirdly, errors have been reported for

certain EPA reference spectra, so the entire EPA reference spectra data base should be suspect.

CAI Model 200 O2

/CO2 Analyzer - The CAI Model 200 O2/CO2 analyzer houses two measurement

principles in one instrument. The oxygen concentrations are measured using the parapneumatic

technique. Because of its sp3 electron orbital distribution, an oxygen molecule has an unpaired

electron and hence displays a magnetic orientation. Since other elements that display this magnetic

phenomenon are not common gasses at normal temperatures, the parapneumatic measurement

technique is virtually specific for oxygen. The sample gas flows through a detection cell located in

a very strong magnetic field. The magnetic nature of the oxygen causes the oxygen to move to one

side of the detection cell, inducing a pressure differential proportional to the oxygen concentration

in the detector cell. The analyzer measures this pressure differential, converts the pressure differential

to an electrical signal, and sends the results as output.

The carbon dioxide concentrations are measured using a single-beam photometric system with

a micro flow sensor detector. The micro flow detector is a sealed unit filled with carbon dioxide.The

instrument consists of an infrared light source, a chopper, a measuring cell and a micro flow detector

filled with carbon dioxide. The infrared light emitted backward is reflected by a reflecting surface

and is added to the infrared light emitted forward. Arranged between the infrared light source and

the measuring cell is a chopper blade which rotates to modulate the infrared light beam at regular

frequency. The modulated infrared light beam thus formed passes through the measuring cell filled

with a sample gas where the light energy is partially absorbed or attenuated before it reaches the front
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chamber of the detector. Both the front and rear chambers of the detector are filled with the gas

component to be measured. The infrared light energy is partially absorbed in the front chamber and

residual light is absorbed in the rear chamber, thereby increasing the pressure in both chambers.

Since the detector is designed to produce a pressure difference between the front and rear chambers,

a slight gas flow is produced through a path connecting these chambers with each other. This slight

flow is converted into an AC electrical signal by a micro flow sensor.

5.6.2 Conditioning and Operational Test Periods 

The conditioning and operational test periods will be completed and sampling commenced

once all monitors are found to be acceptable.

5.6.3 Test Requirements

DEECO's extractive measurement system and all sampling and analytical procedures for

testing will conform to the requirements of EPA Methods 2, 3A, and 4 of 40 CFR 60 and EPA

Method 321 of 40 CFR 63.

The extractive monitors require that the effluent gas sample be conditioned to eliminate any

possible interference (water vapor and particulate matter) before being transported and injected into

each analyzer. All components of the sampling system that contact the sample are Type 316 stainless

steel, glass, or Teflon.

A heated probe with an in-stack particulate filter, heated sample lines, moisture removal trap,

a sample pump, and distribution manifold board are used to deliver a representative sample of flue

gas to the analyzers. The sampling probes are constructed of 316 stainless steel and are heated

electrically to maintain the sample temperature above the dew point. 

The sample acquisition and conditioning system also includes two injection ports: (1)

immediately upstream of the analyzers for analyzer linearity checks, and (2) at the outlet of the probe

for the sampling system bias and calibration drift checks. This arrangement provides both ease in

checking the analyzer performance and a means of evaluating the entire monitoring system.

5.6.4 Test Procedures for EPA Method 3A

All analyzers will be subjected to an interference check similar to the procedures in Section

5.4 of EPA Method 20. During calibration, all analyzers’ response will be noted while introducing

each calibration gas. If the sum of the interference responses of the test gases for any of the analyzers

is greater than 2 percent of the applicable span value, corrective measures on the analyzer will be

taken, up to and including replacement of the analyzer.

Calibration procedures will be performed in accordance with EPA methodology. Analyzers

will be calibrated before and after each test and a calibration check will be done between each test

run.
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The pretest calibrations will consist of the following steps:

• Internal (direct) calibration of each analyzer to adjust calibration and check linearity.

• External (through the entire sampling system) calibration to check the system bias on

zero and span gases.

The post test calibration will consist of an external system bias calibration check.

5.6.4.1 Internal Calibration - Each analyzer will be calibrated using a certified zero and span (mid

or high range as necessary) gas. Zero and span gases will be directed to each analyzer through the

appropriate plumbing, the calibration gas flow rates will be adjusted to the correct flow rate and the

analyzer will be adjusted with the appropriate span pot. After the analyzer is properly adjusted the

linearity will be checked using a mid range calibration gas. The maximum allowable limit for

linearity is 2% of the analyzer range. All analyzers will be shown to be linear within these limits

before proceeding.

5.6.3.2 External Calibration - The external calibration bias check will be performed by placing the

CEM system in the sampling mode and injecting a zero and span gas into the sample line at the probe

exit. This check will show if there was any sampling system related bias, and also served as a check

of the integrity of the sample line.

5.6.4 Calibration Gases

DEECO will use EPA Protocol #1 gases for calibration as required by the various reference

methods used in this test program. Calibration gases will be selected from previous experience with

similar sources and/or from information obtained from the facility engineer prior to sampling. Audit

gases, if available from federal or state agencies, will be analyzed.

5.6.5 Test Procedures

At the completion of the pretest calibration routine, the CEM system will be ready for

operation. No further adjustments of sample flow rates, analyzer zero or span adjustments, or other

critical CEM operating parameters will be made until testing and post test calibration are complete.

The CEMs will be allowed to at least 21 minutes to complete each test run. At the completion for

each run, calibration gases nearest to the measured emission levels will be used to check each

instrument.

During each sampling run, a sampling traverse will be performed to ensure the absence of

stratification. Traverse points will be selected that assure acquisition of representative samples over

the stack or duct cross section. A minimum requirement is the establishment of a "measurement line"

that passes through the centroidal area and in the direction of any expected stratification. If this line

interferes with the CEM measurements, the line will be displaced up to 30 cm (12 in.) (or 5 percent

of the equivalent diameter of the cross section, whichever is less) from the centroidal area. Per

Section 6.5.6.3(a) of 40 CFR 75, three traverse points will be located 16.7, 50.0, and 83.3 percent of

the measurement line, and measured equally during each run. Alternatively, per Section 6.5.6.3(b)

of 40 CFR 75, a single sampling point may be used if the concentration of each compound at each

individual traverse point differs by no more than ±5.0 percent from the arithmetic average

concentration for all traverse points.
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Concurrent measurements of flow following EPA Methods 1, 2, 3A, and 4 (Sections 5.1

through 5.5) will be used to determine flue gas emission rates of all target compounds.

5.6.6 Data Acquisition

Data will be recorded on two separate devices. A hard copy will be obtained using a Molytek

2702 strip chart recorder. Data will also be recorded to the hard disk of an IBM compatible computer

utilizing the serial output of the Molytek recorder in conjunction with custom software. Data for each

of the analyzers will be sampled each second with a one-minute average being written to disk. Data

will be further averaged over the test period and corrected for calibration error and drift using a

spreadsheet program.

5.7 Test Procedures for EPA Method 321

The FTIR optics and sample cell will be purged with nitrogen overnight. A backgroung

spectra will be collected will purging nitrogen thorough the cell at a flow rate low enough that the cell

pressure is not elevated above ambient pressure. Next an ethylene Calibration Transfer Standard

(CTS) will be passed thorough the cell, again at a flow rate low enough that the cell pressure is not

elevated above ambient pressure, and spectra will be collected of the CTS gas. By setting the cell

pressure in the software to reflect the ambient pressure, the path length can be verified and adjusted

as needed. 

As part of the HCl analyte spiking procedure, the calibration gas mixture containing HCl and

sulfur hexafluoride (SF6

) will then be passed directly to the cell, again at a flow rate low enough that

the cell pressure is not elevated above ambient pressure. This will establish the undiluted

concentration of the HCl/SF6 mixture to be used in the analyte spike recovery calculations.

Next the heated sample line will be connected directly to the sample cell, and stack gas will

be drawn through the cell prior to the pretest analyte spiking.

The first step in the analyte spiking will be to send the CTS to the sample probe and back

through the sampling system. Spectra of the CTS gas will be collected and the cell pressure setting

in the software will be adjusted as needed to provide the correct CTS reading.

After the CTS check is completed, stack gas will again be sampled to provide a pre-spike

native concentration of HCl.

Next the HCl/SF6

 gas mixture will be directed to the sample probe at a flow rate

approximately 10% of the total sample rate such that the stack gas provides a nominal 10-fold dilution

of the analyte spike. Once a satisfactory spike recovery of 70%-130% has been is achieved, the

HCl/SF6 gas mixture will be turned off. The HCl/SF6 spike will be purged from the system and

additional spectra will be collected from the stack gas to determine the post spike concentration of

the native HCl.
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It should be noted that there are errors in the Method 321 equation used to calculate the

analyte spike recovery. Consequently the following correct equation will be used;

%R

C C

DF

C

DF

t n

s

=

− −













×

×

1

1

1

100

%R = Spike Recovery

Ct = Concentration of the total HCl (spike plus native), ppm,

Cn = Average concentration of the native HCl (pre and post spike), ppm,

Cs = Concentration of the HCl spike, ppm; and

DF = Ratio of the undiluted SF6

 tracer gas concentration to the diluted SF6 measured during

analyte spiking 
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6.0 QA/QC ACTIVITIES

6.1 QC PROCEDURES

Example data sheets for EPA Methods 2 and 4 and EPA Method 3A are provided in Figures

6.1 and 6.2.

Specific QA/QC parameters for each method is provided in Table 6.1 and described in detail

below.

6.1.1 Manual Sampling Equipment

Each item of field test equipment will be assigned a unique, permanent identification number.

An effective preventative maintenance program is necessary to ensure data quality. Each item of

equipment returning from the field will be inspected before it is returned to storage. During the

course of these inspections, items are cleaned, repaired, reconditioned, and recalibrated where

necessary.

Each item of equipment transported to the field for this test program will be inspected again

before being packed to detect equipment problems which may originate during periods of storage.

This minimizes lost time on the job site due to equipment failure.

Occasional equipment failure in the field is unavoidable despite the most rigorous inspection

and maintenance procedures. For this reason, replacement equipment for all critical sampling train

components will be transported to the job site.

6.1.2 Manual Sampling Equipment Calibration

New items for which calibration is required will be calibrated before initial field use.

Equipment whose calibration status may change with use or time will be inspected in the field before

testing begins and again upon return from each field use. When an item of equipment is found to be

out of calibration, it will be repaired and recalibrated or retired from service. All equipment will be

periodically recalibrated in full, regardless of the outcome of these regular inspections.

Calibrations will be conducted in a manner, and at a frequency, which meets or exceeds U.S.

EPA specifications. The calibration procedures outlined in the EPA Methods will be followed.

When these methods are inapplicable, methods such as those prescribed by the American Society for

Testing Materials (ASTM) will be used.

Data obtained during calibrations will be recorded on standardized forms, which will be

checked for completeness and accuracy by the quality assurance manager. Data reduction and

subsequent calculations will be performed using computer facilities. Calculations will be checked

at least twice for accuracy. Copies of calibration forms will be included in the final test report.

Emissions sampling equipment requiring calibration includes pitot tubes, pressure gauges,

thermometers, dry gas meters and barometers. The following sections elaborate on the calibration

procedures to be followed for these items of equipment.
HCl ICR Site-Specific Test Protocol Page: 19

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

Flow rate and Moisture Measurement Data Sheet

Plant and City Date Sampling Location Sample Type Run No.

Operator

Barometric

Pressure

(Pb)

(In. Hg)

Static

Press

(in. H2O)

Ambient

Temp

(deg. F)

Stack

ID

(In.)

Pitot

Cp

DGM

Box No.

DGM

delta H@

DGM Cal

Factor

(gamma)

Probe

 ID

No.

EPA Method 3/3A Data EPA Method 4 Impinger Weights

Oxygen, % Impinger 1 2 3 Sil.Gel

Carbon Dioxide, % Final Wt., g Color

Nitrogen, % Initial Wt., g % Spent

Net Wt., g

Total Collected , g

EPA Method 2 Data EPA Method 4 Sampling Data

Run Time

(24 hr)

Port/Point

ID 

Pitot

delta P

(in. H2O)

Stack

Temp

(deg. F)

Run Time

(24 hr)

DGM

Reading

(cu.ft.)

DGM

delta H 

(in. H2O)

DGM

Temps

(deg. F)

Exit

Temp

(deg. F)

Sample

Train Vac.

(In. Hg)

Initial Leak Rate cfm @ “Hg

Final Leak Rate cfm @ “Hg

Pitot Leak Check

Figure 6.1 Example field data sheet for EPA Methods 2 and 4
HCl ICR Site-Specific Test Protocol Page: 20

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

Plant and City Test Location Date Operator

Cylinder

ID

Gas

Type Value

Internal

Response

Cal

Error

Run No. Run Time

Pre Run

Bias

Percent

Bias

Post Run

Bias

Percent

Bias

Percent

Drift

O2 Zero Zero N2

CC5134 O2 Mid 11.9%

CC117302 O2 Span 21.9%

CO2 Zero Zero N2

CC5134 CO2 Mid 20.4%

CC117302 CO2 Span 35.5%

Figure 6.2 Example field data sheet for EPA Method 3A
HCl ICR Site-Specific Test Protocol Page: 21

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

TABLE 6.1 SUMMARY QA/QC ACTIVITIES

Test Equipment QC Parameter Target

Volumetric Flow Rate Measurement

Pitot Tube Pitot Geometry Within Specifications

Thermocouple <1.5% absolute

Pitot Leak Check stable 15 sec at $4 in. WC

Dry Gas Meters for Particulate Sampling

Dry Gas Meters Initial Calibration 0.95 # γ # 1.05 

individual γ RSD # 2%

Post Test Calibration Check Post test γ # 5%

Post Test Leak Checks <2% of sample rate 

EPA Method 3A

Initial Calibration Zero Gas <2% of Span Gas

Mid Range Gas <2% of Span Gas

Span Gas <2% of Span Gas

Bias Checks Zero Gas <5% of Span Gas

Mid Range Gas <5% of Span Gas

Drift Zero Gas <5% of Span Gas

Mid Range Gas <5% of Span Gas

Method 321 for Hydrogen Chloride

Pre/Post CTS Calibration Precision Pre and post quantification #5% RSD

Direct HCl Calibration Precision Duplicate measurement #5% RSD

HCl Analyte Spike System Validation Spike Recovery 70% - 130%
HCl ICR Site-Specific Test Protocol Page: 22

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

A: Pitot Tubes. All Type S pitot tubes used, whether separate or attached to a sampling

probe, will be constructed in-house or by a third-party vendor. Each new pitot will be

calibrated in accordance with Section 10.1 of EPA Method 2. Each Type-S pitot tube,

calibrated according to these standards, will have an assigned coefficient. This

coefficient should not change as long as the pitot tube is not damaged.

 

 Each pitot tube will be inspected visually upon return from the field. If a cursory

inspection indicates damage or raises doubt that the pitot remains in accordance with

the EPA geometry standards, the pitot tube will be refurbished as needed and

recalibrated.

B: Differential Pressure Gauge. All meter consoles used are equipped with 10-inch

water column (W.C.) inclined-vertical manometers. Fluid manometers do not require

calibration other than leak checks. Manometers will be leak checked in the field prior

to each test series, and again upon return from the field.

C: Impinger Thermometer. Prior to the start of testing, the thermocouple used to

monitor the temperature of the gas leaving the last impinger will be compared with a

mercury-in-glass thermometer which meets ASTM E-1 No. 63F specifications. The

impinger thermocouple is replaced if it does not agree within 2EF of the reference

thermometer. After each field use, the thermocouple will be checked per EPA Alt-011

procedures.

D: Dry Gas Meter Thermometer. The thermocouple used to measure the temperature

of the metered gas sample will be checked prior to initial field use against an ASTM

mercury-in-glass thermometer. The dry gas meter thermocouple is acceptable if the

values agree within ±2EF. Thermocouples not meeting this requirement will be

replaced. After each field use, the thermocouple will be checked per EPA Alt-0011

procedures.

E: Flue Gas Temperature Sensor. All thermocouples employed for the measurement

of flue gas temperature are calibrated upon receipt. Initial calibrations will be

performed at three points (ice bath, boiling water, and hot oil). An ASTM mercury-inglass thermometer will be used as a reference. The thermocouple is acceptable if the

agreement is within 1.5 percent (absolute) at each of the three calibration points.

After each field use, the thermocouple will be checked per EPA Alt-011 procedures.

Before each field use, the reading from the flue gas thermocouple-potentiometer

combination will be compared with an ASTM mercury-in-glass reference

thermometer at ambient conditions. If the two agree within ±1.5 percent (absolute),

the thermocouple and potentiometer are considered to be in proper working order.

F: Dry Gas Meter and Orifice. Two procedures will be used to calibrate the dry gas

meter and orifice simultaneously. The full calibration will be a complete laboratory

procedure used to obtain the calibration factor of the dry gas meter. Full calibrations

will be performed over a wide range of orifice settings. A simpler procedure, the posttest calibration, will be designed to check whether the calibration factor has changed.
HCl ICR Site-Specific Test Protocol Page: 23

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

A dry gas meter that is calibrated annually against a spirometer or a set of calibrated

critical orifices will be used as a transfer standard. During the annual calibration,

triplicate calibration runs will be performed at seven flow rates ranging from 0.25 to

1.40 cfm.

G: Dry Gas Meter. Each metering system receives a full calibration at the time of

purchase and a post-test calibration after each field use. If the calibration factor, γ,

deviates by less than five percent from the initial value, the test data are acceptable.

If γ deviates by more than 5 percent, the meter is recalibrated and the meter coefficient

(initial or recalibrated) that yields the lowest sample volume for the test runs is used.

EPA Method 5 requires another full calibration anytime the post-test calibration check

indicates that γ changed by more than 5 percent. Standard practice is to adjust and

recalibrate the dry gas meter anytime γ is found to be outside the range of 0.96 to 1.04.

Post-test calibrations will be performed after each field test series per EPA Alt-009

procedures.

H: Orifice. An orifice calibration factor will be calculated for each flow setting during

a full calibration. If the range of values does not vary by more than 0.15 in H2O over

the range of 0.5 to 4.0 in H2O, the arithmetic average of the values obtained during the

calibration is used.

I: Barometer. Each field barometer will be adjusted before each test series to agree

within ±0.1 inches of a reference mercury-column barometer. The reference

barometer will be checked against the station pressure value (corrected for elevation

difference) reported by the National Weather Service.

6.1.3 Manual Sampling Quality Control Procedures

The following pretest QC checks will be conducted:

• All sampling equipment will be thoroughly checked to ensure clean and operable

components.

• Equipment will be inspected for possible damage from shipment.

• The oil manometer or Magnehelic gauge used to measure pressure across the Type S

pitot tube will be leveled and zeroed.

• The number and location of the sampling traverse points will be checked before taking

measurements.

• The temperature measurement system will be visually checked for damage and

operability by measuring the ambient temperature prior to each run.

In addition to the general QC procedures listed above, QC procedures specific to each

sampling method will also be incorporated into the sampling scheme. These methods and specific

procedures are discussed below.
HCl ICR Site-Specific Test Protocol Page: 24

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

A: Sampling Train QC checks. The following QC procedures will be emphasized:

Prior to Start of Tests

• Keep all cleaned glassware and sample train components sealed until train

assembly.

• Assemble the sampling trains in an environment free from contamination. 

• Visually inspect each sampling train for proper assembly.

• Perform pretest calculations to determine the proper sampling nozzle size.

Prior to Each Test Run

• Visually inspect the sampling nozzle.

• Visually inspect the Type S pitot tube.

• Leak check each leg of the Type S pitot tube.

• Leak check the entire sampling train.

During Each Test Run

• Readings of temperature and differential pressure will be taken at each

traverse point.

• All sampling data and calculations will be recorded on preformatted data

sheets.

• All sampling data forms will be reviewed for completeness and accuracy.

• Any unusual occurrences will be noted during each run on the appropriate data

form.

• The project supervisor will review sampling data sheets daily during testing.

• Properly maintain the roll and pitch axis of the Type S pitot tube and the

sampling nozzle.

• Leak check the train before and after any move from one sampling port to

another during a run (at DEECO’s option) or if a filter change takes place.

• Maintain the probe, filter, and impingers at the proper temperatures.

• Maintain ice in the ice bath at all times.

• Make proper readings of the dry gas meter, delta P and delta H, temperature,

and pump vacuum during sampling at each traverse point.

• Maintain isokinetic sampling within ± 10% of 100%.

After Each Test Run

• Visually inspect the sampling nozzle.

• Visually inspect the Type S pitot tube.

• Leak check each leg of the Type S pitot tube.

• Leak check the entire sampling train.

B: QC for Volumetric air flow rate determinations
HCl ICR Site-Specific Test Protocol Page: 25

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

Flue Gas Velocity. Data required to determine the flue gas velocity will be collected

using the methodology specified in EPA Method 2. Quality control procedures are

as follows.

• Visually inspect the Type S pitot tube before and after sampling.

• Leak check both legs of the pitot tube before and after sampling.

• Check the number and location of the sampling traverse points before taking

measurements.

Flue Gas Molecular Weight. Samples to be used for determination of flue gas

molecular weight will be collected using the continuous sampling technique specified

in EPA Method 3A. Quality control will focus on the following procedures:

• The sample acquisition system will be leak checked before operation.

• A constant sampling rate will be used in withdrawing a sample.

• The sampling port will be properly sealed to prevent air in-leakage.

Moisture Content. The moisture content of the gas stream will be determined using

the technique specified in EPA Method 4. The following QC checks will be

performed:

• The sampling train will be leak checked before and after each run.

• Ice will be maintained in the ice bath throughout each run.
HCl ICR Site-Specific Test Protocol Page: 26

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

7.0 REPORTING AND DATA REDUCTION REQUIREMENTS

7.1 Report Format

TABLE OF CONTENTS

1.0 Introduction 

1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

1.2 Key Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.0 Source and Sampling Location Descriptions

2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.3 Flue Gas and Process Sampling Locations . . . . . . . . . . . . . . . . . . . . . . . . X

3.0 Summary and Discussion of Results

3.1 Objectives and Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

3.2 Field Test Changes and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

3.3 Summary of Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

4.0 Sampling and Analytical Procedures 

4.1 Emission Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

4.2 Process Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

5.0 QA/QC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

APPENDICES

A - Results and Calculations

B - Raw Field Data

C - CEM Results

D - FTIR Results

E - Equipment Calibration Data Sheets and Calibration Certificates of Analysis

F - List of Participants
HCl ICR Site-Specific Test Protocol Page: 27

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

7.2 Data Reduction and Summary

An example data summary table is shown as Table 7.1.

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLORIDE

EMISSION TEST RESULTS, HOLCIM (US) DEVILS SLIDE FACILITY,

RAW MILL OFF CONDITION; FEBRUARY 24, 2010 

Test Parameter Run X Run X Run X Average

Time xx:xx-xx:xx xx:xx-xx:xx xx:xx-xx:xx ----

Stack Gas Temperature (EF) xxx xxx xxx xxx 

Stack Gas Moisture x.x% x.x% x.x% x.x%

Volumetric Flowrate

 actual cfm

 dry standard cfm

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

Oxygen Content x.x% x.x% x.x% x.x%

Hydrogen Chloride Emissions

 Concentration, ppmby volume, wet basis

 Concentration, ppmby volume, dry basis

 Concentration, ppm at 7% oxygen

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx
HCl ICR Site-Specific Test Protocol Page: 28

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

8.0 PLANT ENTRY AND SAFETY

8.1 Safety Responsibilities

The DEECO Safety Officer (Dr. Scott Steinsberger) is responsible for ensuring compliance

with plant entry, health, and safety requirements.

The Holcim Devils Slide Plant Contact (Kevin Ovard) has the authority to impose or waive

facility restrictions.

The DEECO Test Director (Dr. Scott Steinsberger) has authority to negotiate with facility

person any deviations from the facility restrictions.

8.2 Safety Program

The DEECO Health and Safety Program is attched as Appendix A.

8.3 Safety Requirements

All test personnel will adhere to the following standard safety and precautionary measures

as follows:

C Confine selves to test area only.

C Wear hard hats at all times on-site, except inside sample recovery trailers

and mobile CEM laboratory.

C Wear protective shoes or boots in test area.

C Wear protective glasses or goggles at the test sites, and other areas as

designated.

C Have readily available first aid equipment and fire extinguishers.

Before or on the first day on-site, the Test Director will fill out the Holcim

Contractor Job Safety Plan and the Pre-Shift Hazard Assessment form and provide

copies to be posted at each test site.
HCl ICR Site-Specific Test Protocol Page: 29

Holcim (US) Inc. Revision No: 0

Devils Slide, Utah Date: February 20,2010

9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE 

9.1 Test Site Organization

The key tasks and task leaders are:

C Management: William G. DeWeeS

C Test Preparation/Site Restoration: Scott C. Steinsberger

C Modifications to Facility/Services:Kevin Ovard

C Sampling Site Accessibility: Kevin Ovard

C Sample Recovery: John Martin

C Daily Sampling Schedule: Scott C. Steinsberger

9.2 Test Preparations

No special sampling and analytical equipment is needed. No modifications to the facility are

needed. Suitable safe access to the sampling location currently exists. Holcim will provide the

necessary electrical power. Sample recovery of the Method 4 trains will be conducted in a mobile

recovery laboratory already on-site.

9.3 Test Personnel Responsibilities and Detailed Schedule

DEECO personnel will arrive at the plant about 1.5 hours before the start of the first test run

on each of the two days scheduled for sampling. Pre-test activities on these days will include:

C Meet with the plant contact to review the daily test objectives.

C Prepare and set-up (including leak checks) the manual method trains at all test locations.

C Calibrate instrumental analyzers and verify that the data acquisition systems are

functioning properly.

C Verify communication links between team members/leaders/plant personnel.
Appendix A

DEECO Health and Safety Plan
DEECO Inc.

3404 Lake Woodard Road

Raleigh, NC 27604

(919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com

DEECO

HEALTH AND SAFETY PLAN

January 2010
DEECO

Health and Safety Plan

Section Page

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Employee Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1.3 Pre-Work Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1.4 Employee Safety Education, Training, and Evaluation . . . . . . . . . . . . . . . . . . . . . 4

2.0 General Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.1 First Aid for Accidents and Injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.2 Audit/Inspection Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2.3 Bloodborne Pathogens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.4 Aerial Devices (Man Lifts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.6 Documented Safety Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.8 Electrical - GFCI or Grounding Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

2.9 Equipment Inspection/Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.10 Excavation/Trenching/Shoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.11 Floor/Wall Openings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.12 Hearing Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.13 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.14 Manual Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.15 Mechanical Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.16 Mechanical and Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.17 New Employee Orientation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.18 Power and Hand Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.19 Process Safety Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.20 Scaffolding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.21 Stairways and Ladders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

2.22 Travel Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.23 Thermal Stress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.24 Welding and Cutting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

2.26 Lockout/Tagout (LOTO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

2.27 Fall Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen

Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

2.29 Emergency Response/Evacuation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

2.30 Compressed Air Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

2.31 Concrete Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

2.32 Powder-Actuated Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
Section Page

3.0 Chemical Safety Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

3.1 General Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

3.2 Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.3 Bases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.4 Compressed Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

3.5 Cryogenic Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

3.6 Flammable Liquids and Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

3.7 Organic Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

3.8 Oxidizing Agents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

3.9 Asbestos Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

3.10 Benzene Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

3.11 Hydrogen Sulfide Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

3.12 Lead Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

4.0 Hazard Communication Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

4.1 Material Safety Data Sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

4.2 Chemical Labelling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

4.3 Employee Exposure Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

4.4 Employee Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

4.5 Employee Access to Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

5.0 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

5.1 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

5.2 Gloves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

5.3 Protective Eyewear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

5.4 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

5.5 OSHA Levels of Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

5.5 Training for the Use Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . 70
DEECO Health and Safety Plan Page 1 January 2010

1.0 Introduction

DEECO, Inc. (DEECO) is committed to the health and safety of its employees. In order to ensure

that all tasks are performed safely, this Health and Safety Plan (HSP) has been prepared. The

procedures detailed in this HSP outline individual responsibilities, specific operating procedures,

training requirements, and specific information on potential safety and health hazards.

The hazards faced by DEECO field personnel are varied, and specific controls of many hazards are

the responsibility of the client. This HSP will enable employees to recognize potential hazards so

that the client may take actions to correct the condition before the work is performed. This HSP also

identifies DEECO activities which may pose significant health and safety risks. 

1.1 Responsibilities

This section details the responsibilities for employees and management in the implementation of the

HSP.

President

The President of DEECO has overall responsibility for compliance with all applicable federal and

state regulations and the provisions of this HSP. Periodic meetings with managers and employees

should be conducted to discuss:

# The importance of health and safety.

# Changes in regulations regarding health and safety.

# Recent employee monitoring results.

# Any recent employee accidents/injuries and possible preventive measures to avoid

a recurrence.

In addition to the above responsibilities, the President is responsible for authorizing any deviations

from the HSP.

Managers

Project managers and field team leaders are responsible for the health and safety of all persons

assigned to the specific project. Project managers and field team leaders must ensure that:

# Employees are properly trained to perform all tasks in a safe manner.

# Proper personal protective equipment are available and in good working condition.

# Persons using personal protective equipment have been instructed on their use.

# Emergency equipment is available and in good working condition.

# Employees are informed of any exposure monitoring performed in their work area

that may be representative of their chemical exposure.

# All safety considerations have been discussed with the client prior to mobilization.

# All aspects of the projects have been discussed and are understood with the team

leader and team members.

# All appropriate safety equipment is available and in good working condition prior to

mobilization.

# All records (employee training, respirator fit-testing, etc.) are present for all team
DEECO Health and Safety Plan Page 2 January 2010

members.

# Copies of MSDSs for all chemicals used by DEECO are available for the client.

# All tasks are performed in a safe manner.

# All accidents, injuries, or spills are reported immediately.

# Any unsafe condition is reported immediately.

# They cooperate with any monitoring surveys.

DEECO Safety Officer

The DEECO Safety Officer (SO) is responsible for the review and maintenance of the Health &

Safety Plan. In addition, the SO is responsible for:

# Identifying when employee exposure monitoring is necessary.

# Writing exposure reports and reporting results to the appropriate department manager

and employees.

# Ensuring that appropriate employee training is provided.

# Investigating reported accidents with department managers.

# Ensuring that new information on health, safety, employee training, or changes in

legal requirements are conveyed to the Director of Field Services. 

1.2 Employee Conduct

Appropriate employee conduct is essential in conveying a professional image to DEECO clients.

When performing work on client premises:

# Dress professionally.

# Contact the team leader if problems with a client arises.

# Discuss disagreements with other DEECO personnel in private, not in front of the

client.

# Do not discuss DEECO company policies or practices with clients (e.g. management,

compensation. etc.)

# Direct all questions regarding sampling or project activities to the team leader.

# Do not convey DEECO in a negative manner to clients. Any disagreements with

company practices should be discussed directly with your manager.

# Do not volunteer data to client employees.

# Release data only to the designated client contact.

# Do not promise a date for the final report. Have the client contact the project

manager or coordinator for a final report date.

# Remain busy while on the client's premises.

# Remain within designated areas of plant site.

# Notify team leader when leaving area.

# Notify client when leaving site for lunch or the end of the day.

# Be on time for client meetings. If problems arise, call the client immediately if the

scheduled time cannot be kept.

# Follow all rules and regulations of the client while on the plant site.

# If approached by the news media, do not offer any information. Refer all questions

to the client.
DEECO Health and Safety Plan Page 3 January 2010

Drugs and Alcohol Use

It is DEECO's desire to provide a drug-free, healthful, and safe workplace. To promote this goal,

employees are required to report to work in appropriate mental and physical condition to perform

their jobs in a satisfactory manner.

While on DEECO premises and while conducting business-related activities off DEECO premises,

no employee may use, possess, distribute, sell, or be under the influence of alcohol or engage in the

unlawful manufacture, distribution, dispensation, possession, or use of illegal drugs. Violations of

this policy may lead to disciplinary action, up to and including immediate termination of

employment, and/or required participation in a substance abuse rehabilitation or treatment program.

Such violations may also have legal consequences.

The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's

ability to perform the essential functions of the job effectively and in a safe manner that does not

endanger other individuals in the workplace.

To inform employees about important provisions of this policy, DEECO has established a drug-free

awareness program. The program provides information on the dangers and effects of substance

abuse in the workplace, resources available to employees, and consequences for violations of this

policy.

Employees with questions or concerns about substance dependency or abuse are encouraged to

discuss these matters with their supervisor or the Personnel Director to receive assistance or referrals

to appropriate resources in the community.

Employees with drug or alcohol problems that have not resulted in, and are not the immediate

subject of, disciplinary action may request approval to take unpaid time off to participate in a

rehabilitation or treatment program through DEECO's health insurance benefit coverage. Leave may

be granted if the employee agrees to abstain from use of the problem substance; abides by all

DEECO policies, rules, and prohibitions relating to conduct in the workplace; and if granting the

leave will not cause DEECO any undue hardship.

Under the Drug-Free Workplace Act, an employee who performs work for a government contract

or grant must notify DEECO of a criminal conviction for drug-related activity occurring in the

workplace. The report must be made within five days of the conviction.

Employees with questions on this policy or issues related to drug or alcohol use in the workplace

should raise their concerns with their supervisor or the Personnel Director without fear of reprisal.

Abusive Language

Abusive or vulgar language, ethnic or sexual slurs and insults will not be tolerated on client or

DEECO premises. Use of such language is not only offensive, but may be seen as illegal

harassment. Inappropriate language or insults can result in immediate, appropriate action upon the

employee by DEECO. If problems with employee use of such language occurs, notify your manager.
DEECO Health and Safety Plan Page 4 January 2010

1.3 Pre-Work Safety Considerations

The Project Coordinator or Manager should determine through a site visit, or through extensive

conversations with the client, if any unusual safety hazards exist at the work site. Additional

equipment, if needed, should be determined by the Project Coordinator/Manager and the DEECO

S.O.

1.4 Employee Safety Education, Training, and Evaluation

All DEECO personnel shall initially receive the equivalent of the OSHA 40-hour Training for

Hazardous Waste Operators. The 8-hour Refresher Training shall be completed annually by all

personnel.

Additional training and education may be required for specific job responsibilities. The training

requirements for additional education shall be set by the President.

Employee Safety Evaluation Program

An annual evaluation of each employee’s safety performance will be conducted.

Evaluating an employee’s safety performance involves measuring the level at which employees are

achieving both their own personal safety goals and the company’s expected safety performance

standards. Integrating health and safety into a performance appraisal system provides management

with a unique opportunity to tie the employee’s accountabilities and achievements to the company’s

objectives and strategic plans. 

The goals of the Employee Safety Evaluation Program are;

1. Communicating information to employees on how well they are meeting the health and

safety performance expectations of their jobs;

2. Identifying areas for coaching to help employees improve their health and safety performance

and develop safe work practices;

3. Providing opportunities to further communicate the organization’s health and safety

performance expectations;

4. Supporting the organizational succession plan;

5. Providing feedback to the organization about its recruitment and selection process as well

as its integrated health and safety training/development program; 

6. Providing feedback about the employee’s perceptions of the company’s health and safety

performance and standards. 

For employees, meeting the health and safety expectations of a job requires them to:

1. Report hazards or hazardous conditions to their supervisor;
DEECO Health and Safety Plan Page 5 January 2010

2. Work in a safe manner at all times by using appropriate protective gear and controls on

equipment;

3. Follow company policies and procedures;

4. Wear personal protective equipment as instructed;

5. Participate in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)

For supervisors, meeting the health and safety expectations of a job requires the ability to: 

1. Coach employees on safe work practices;

2. Enforce company policies and procedures;

3. Act as a positive role model for staff with respect to safe work practices;

4. Support any staff who are members of the joint health and safety committee;

5. Be aware of their legal requirements under the Occupational Health and Safety Act;

6. Review new jobs/tasks/processes/equipment for safety concerns;

7. Follow-up on reported concerns in a timely fashion;

8. Encourage employee input into safety-related concerns and solution-finding processes; and

9. Discipline staff when required for failure to follow safety procedures.

The Employee Safety Evaluation Program will quantify the health and safety areas being monitored

and provide qualitative feedback on employee health and safety performance.

The Employee Safety Evaluation Program will evaluate a employee’s performance on the following;

1. Reporting hazards or hazardous conditions to their supervisor;

2. Working in a safe manner at all times by using appropriate protective gear and controls on

equipment;

3. Following company policies and procedures;

4. Wearing personal protective equipment as instructed;

5. Participating in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)

The Employee Safety Evaluation Program will evaluate a supervisor’s performance on the following;
DEECO Health and Safety Plan Page 6 January 2010

1. Effectiveness in managing health and safety issues in their department or area of

responsibility; and

2. Establishing specific criteria for minimum health and safety standards.
DEECO Health and Safety Plan Page 7 January 2010

2.0 General Safety Requirements

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

safety procedures, field personnel are to follow the procedures which are more stringent. In all cases,

all OSHA, MSHA and/or EPA requirements shall be met.

2.1 First Aid for Accidents and Injuries

In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible in terms

of time and distance to the worksite, which is available for the treatment of injured employees, a

person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American

Red Cross, or equivalent training that can be verified by documentary evidence, shall be available

at the worksite to render first aid. 

First aid supplies shall be easily accessible when required. The contents of the first aid kit shall be

placed in a weatherproof container with individual sealed packages for each type of item, and shall

be checked by the employer before being sent out on each job and at least weekly on each job to

ensure that the expended items are replaced.

Proper equipment for prompt transportation of the injured person to a physician or hospital, or a

communication system for contacting necessary ambulance service, shall be provided.

In areas where 911 is not available, the telephone numbers of the physicians, hospitals, or

ambulances shall be conspicuously posted.

Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable

facilities for quick drenching or flushing of the eyes and body (e.g. safety showers and emergency

eyewash systems) shall be provided within the work area for immediate emergency use. The

location of these facilities for quick drenching or flushing of the eyes and body shall be identified

and all employees in the affected area will be shown the location of these facilities.

The reporting of any work-related accident, illness, or injury is required by Worker's Compensation

regulations. North Carolina law requires that a manager's report on an accident or injury be filed

within 10 days after the incident.

The reporting of incidents will enable employees and management to determine what possible

corrective actions can be taken to avoid a recurrence of the incident.

Responsibilities

Project managers or coordinators must ensure that:

# Immediate care is obtained for all accidents or injuries.

# All employee accidents or injuries are recorded on the DEECO Accident Report form

by the employee.

# Copies of the Accident Report form are sent to the Personnel Director and the

DEECO S.O.
DEECO Health and Safety Plan Page 8 January 2010

# Accident reports are reviewed with the employee and possible preventive measures

are noted and implemented if required.

# Any equipment involved in an incident is removed from service until repaired or

replaced.

The Personnel Director must ensure that:

# Necessary North Carolina forms are completed, distributed, and maintained for any

occupational injury or accident.

# The OSHA Form 300 is updated and posted on the bulletin board in the Break Room.

Employees must ensure that:

# All accidents or injuries are reported immediately to the Department Manager,

Project Manager, or Project Coordinator.

# All details of the accident or injury are recorded on the DEECO Accident Report

form.

2.2 Audit/Inspection Procedures

Safety audits and inspections of all work areas will be conducted periodically by the Safety Officer

or a representative thereof. Procedures for conducting an inspection of a job site will be as follows.

The following items, while not inclusive, are indicators of some of the areas of concern for good job

site safety covered in a routine inspection or audit.

Item Acceptable Not Acceptable NA

Employee Safety Training ( ) ( ) ( )

Safety Manual On site ( ) ( ) ( )

Assigned Responsibilities ( ) ( ) ( )

Confined Space Entry ( ) ( ) ( )

Fire Protection ( ) ( ) ( )

Electrical - GFCI or Grounding Program ( ) ( ) ( )

Equipment Inspection/Maintenance ( ) ( ) ( )

Excavation/Trenching/Shoring ( ) ( ) ( )

Floor/Wall openings ( ) ( ) ( )

Hearing Conservation ( ) ( ) ( )

Housekeeping ( ) ( ) ( )

Mechanical Lifting ( ) ( ) ( )

Mechanical and Electrical Safety ( ) ( ) ( )

Power Tools ( ) ( ) ( )

Scaffolding ( ) ( ) ( )

Stairways and Ladders ( ) ( ) ( )

Travel Safety Followed ( ) ( ) ( )

Thermal Stress ( ) ( ) ( )

Chemical Safety Guidelines Met ( ) ( ) ( )

Hazard Communication Requirements Met ( ) ( ) ( )

Material Safety Data Sheets On site ( ) ( ) ( )

Chemical Labelling Clear and correct ( ) ( ) ( )

Personal Protective Equipment ( ) ( ) ( )
DEECO Health and Safety Plan Page 9 January 2010

Respiratory Protection ( ) ( ) ( )

Gloves ( ) ( ) ( )

Protective Eyewear ( ) ( ) ( )

Protective Clothing ( ) ( ) ( )

Fall Protection ( ) ( ) ( )

2.3 Bloodborne Pathogens

In the normal course of work, it is not reasonably anticipated that DEECO employees will encounter

occupational exposure of the skin, eye, mucous membrane, or parenteral contact with blood or other

potentially infectious materials. Consequently, DEECO is not required to have a written Exposure

Control Plan.

However, in the case of an accident, all contact with blood or blood products should be avoided to

prevent the risk of exposure to bloodborne pathogens, . Cuts, scrapes, and abrasions should be

reported to the safety officer or appointed representative and proper health care should be provided

by trained personnel. Rubber gloves should be worn at all times when treating injuries causing risk

to bloodborne pathogens. 

Rubber gloves, protective resuscitation masks, and other first aid items are contained in the field first

aid kit which is to be present on each project.

2.4 Aerial Devices (Man Lifts)

On occasions, DEECO employees may be required to use aerial devices (man lifts) to access

sampling locations. The following are examples of aerial devices;

1. An aerial device is any vehicle-mounted device, telescoping or articulating, or both, which

is used to position personnel;

2. An aerial ladder is an aerial device consisting of a single- or multiple-section extensible

ladder;

3. An articulating boom platform is an aerial device with two or more hinged boom sections.;

4. An extensible boom platform is an aerial device (except ladders) with a telescopic or

extensible boom. Telescopic derricks with personnel platform attachments shall be

considered to be extensible boom platforms when used with a personnel platform;

5. An insulated aerial device is an aerial device designed for work on energized lines and

apparatus;

5. A mobile unit is a combination of an aerial device, its vehicle, and related equipment;

6. A platform is any personnel-carrying device (basket or bucket) which is a component of an

aerial device;

7. A vehicle is any carrier that is not manually propelled; and
DEECO Health and Safety Plan Page 10 January 2010

8. A vertical tower is an aerial device designed to elevate a platform in a substantially vertical

axis.

Specifc Requirements for Aerial Lifts

Only trained persons shall operate an aerial lift.

For ladder trucks and tower trucks, before the truck is moved for highway travel, aerial ladders will

be secured in the lower traveling position by the locking device above the truck cab, and the

manually operated device at the base of the ladder, or by other equally effective means (e.g., cradles

which prevent rotation of the ladder in combination with positive acting linear actuators).

For extensible and articulating boom platforms, the lift controls shall be tested each day prior to use

to determine that such controls are in safe working condition.

Belting off to an adjacent pole, structure, or equipment while working from an aerial lift shall not

be permitted.

Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge

of the basket or use planks, ladders, or other devices for a work position.

A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial

lift.

Boom and basket load limits specified by the manufacturer shall not be exceeded.

The brakes shall be set and outriggers, when used, shall be positioned on pads or a solid surface.

Wheel chocks shall be installed before using an aerial lift on an incline.

An aerial lift truck may not be moved when the boom is elevated in a working position with men in

the basket, except for equipment which is specifically designed for this type of operation in

accordance with the provisions of OSHA 1910.67, paragraphs (b)(1) and (b)(2).

Articulating boom and extensible boom platforms, primarily designed as personnel carriers, shall

have both platform (upper) and lower controls. Upper controls shall be in or beside the platform

within easy reach of the operator. Lower controls shall provide for overriding the upper controls.

Controls shall be plainly marked as to their function. Lower level controls shall not be operated

unless permission has been obtained from the employee in the lift, except in case of emergency.

Climbers shall not be worn while performing work from an aerial lift.

The insulated portion of an aerial lift shall not be altered in any manner that might reduce its

insulating value.

Before moving an aerial lift for travel, the boom(s) shall be inspected to see that it is properly cradled

and outriggers are in stowed position, except as provided in OSHA 1910.67, paragraph (c)(2)(viii).
DEECO Health and Safety Plan Page 11 January 2010

2.5 Confined Space Entry

A Confined Space in an enclosure having limited access and egress. Examples of confined spaces

include, but are not limited to:

# Storage tanks, tank cars, process vessels, bins, silos, boilers, and other tank-like

compartments usually with only a manhole for entry.

# Open-topped spaces of more than 4 feet in depth, such as pits, vaults and vessels, not

subject to good natural ventilation.

# Septic tanks, sewers, underground utility tunnels, pipelines, and similar structures.

Confined spaces may contain atmospheres that are hazardous to life and health because of the

presence of flammable, explosive, or toxic contaminants or because of either a deficiency or excess

of oxygen. It is DEECO policy not to permit employees to enter a confined space. In the event that

confined space entry is necessary as part of a project, the client is to provide DEECO personnel with

training, life-support equipment, and emergency/rescue personnel during any confined space work.

2.6 Documented Safety Meetings

Safety Meetings will be held on the first day of a project, on-site. A review of safety conditions will

be made by the project manager/field team leader at the end of each day's work. Any unusual or

notable health or safety concerns will be noted in the field log, and discussed with all field team

members. All field safety meetings will be documented in the field log book, and a copy of the

appropriate pages will be included in the final written report to the client.

The President shall ensure that meetings are held periodically to address safety violations,

procedures, and/or updates. The dates, attendees, and topics of these meetings will be documented

and placed in the Safety Meetings file.

2.7 Fire Protection

Every employee should be aware of the combustible characteristics of the chemicals and materials

they use or may come in contact with. This information can be found on the chemical's Material

Safety Data Sheet (MSDS), or labels on the material container.

When performing work on a client's site, the Project Manager or Coordinator must:

# Be able to clearly identify all regular and emergency exits in the building or work

area.

# Receive a site evacuation route from the client.

# Receive emergency notification procedures from the client (e.g. number to call in

case of fire, explosion, etc.).

# Ensure all team members are aware of the above information.

Care should be taken when storing or using chemicals or hazardous materials in DEECO vehicles

or mobile laboratories. All vehicles and mobile laboratories are equipped with fire extinguisher.

If a fire should occur:

# Aim fire extinguisher at the base of the fire.

# Never allow the fire to come between you and an exit.

# Never use water on electrical or burning liquid fires.

If the fire is too large to be contained with one fire extinguisher:
DEECO Health and Safety Plan Page 12 January 2010

# Immediately notify the site emergency contact. Report location of fire, material

burning, and if any injuries are involved.

# Evacuate the area.

Fire Extinguisher Classes

Class A - for use on ordinary combustible materials such as paper, wood, etc.

Class B - for use on flammable and combustible liquids, greases, paints, etc.

Class C - for use on electrical fires.

Class D - for use on combustible metals.

All fire extinguishers located in the DEECO vehicles and mobile laboratories are rated for Class A,

B, and C fires.

2.8 Electrical - GFCI or Grounding Program

It is the policy of DEECO to establish and implement an assured equipment grounding conductor

program on work sites covering all cord sets, receptacles which are not a part of the permanent

wiring of the building or structure, and equipment connected by cord and plug which are available

for use or used by employees. This policy shall apply to all work sites not equipped with ground

fault circuit interrupters in accordance with OSHA standard 1926.400 (h).

The project manager/field team leader shall implement the assured equipment grounding conductor

program where existing and predictable hazards are identifyedi the surrounding area or working

conditions which are unsanitary, hazardous or dangerous to employees, and who is authorized to take

prompt corrective measures to eliminate them.

The project manager/field team leader shall be responsible and accountable for the following:

Each cord set, attachment cap, plug and receptacle of cord set and any equipment connected by cord

and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be

visually inspected before each day's use for external defects, such as deformed or missing pins, or

insulation damage, and for indication of possible internal damage. Equipment found damaged or

defective may not be used until repaired.

The project manager/field team leader is responsible for tests on all cord sets, receptacles which are

not a part of the permanent wiring of the building or structure, and cord and plug connected

equipment repaired to be grounded. Tests shall be documented on the log for assured equipment

grounding conductor program and shall be on the job site for inspection by OSHA officials and any

affected employee. Equipment that does not meet prescribed test shall not be put into service. The

following tests shall be performed:

1. All equipment grounding conductors shall be tested for continuity and shall be electrically

continuous.
DEECO Health and Safety Plan Page 13 January 2010

2. Each receptacle and attachment cap or plug shall be tested for correct attachment of the

equipment grounding conductor. The equipment grounding shall be connected to its

terminal..

In accordance with OSHA Construction Safety and health Standards 1926.21 Safety Training and

Education, project manager/field team leader shall attend such training sessions as the company may

deem necessary.

A copy of this policy shall be at the job site for inspection and copy by OSHA officials and any

affected employee. Management retains the authority to designate that certain jobs comply with

regulation 1926.400 (h) by use of ground fault circuit interrupters in lieu of the program established

above. A copy of the completed forms will be kept on each applicable job site for inspection

purposes.

Electric power operated tools and power cords shall be UL approved, double insulated or have the

third wire ground whole and in place. All 120-volt single phase, 15- and 20-ampere receptacle

outlets on construction sites, which are not a part of the permanent wiring of the building or structure

and which are in use by employees, shall have approved ground-fault circuit interrupters (GFCI) for

personnel protection.

All equipment and power cords are to be inspected prior to the field project. Any equipment or

power cord which is not in proper working order shall be tagged as "DAMAGED-DO NOT USE"

and returned to the DEECO laboratory for repair or replacement.

2.9 Equipment Inspection/Maintenance

Mechanical and electrical equipment will be periodically inspected according to the manufacturers

instructions to ensure they are in proper working order, all cords and parts are not chipped, frayed

or broken, and recommended maintenance procedures are conducted on schedule. Equipment that

does not meet safety standards will be repaired or replaced before use.

2.10 Excavation/Trenching/Shoring

DEECO personnel shall not perform excavation or trenching work, nor shall DEECO personnel be

expected to enter an excavation or trench. Should such entry be required on a project, the client must

ensure:

- Underground lines, equipment and electrical cables shall be located, identified and

de-energized prior to beginning work.

- Walls and faces of trenches and excavations, four or more feet deep, are shored,

sloped or shielded as dictated by the type of soil encountered.

- Daily inspections are conducted by a competent person for evidence of a situation

that could result in possible cave-ins, indications of failure of protective systems or

other hazardous conditions.

- Employees are not be permitted underneath loads handled by lifting or digging

equipment. Employees shall be required to stand away from any vehicle being

loaded or unloaded.
DEECO Health and Safety Plan Page 14 January 2010

- Employees are be protected from excavated or other materials and equipment that

could pose a hazard by falling or rolling in excavations.

 - Physical barriers are be placed around or over trenches and excavations. Barriers

shall be removed only when necessary to provide access to personnel or equipment.

Flashing light barricades shall be provided at night.

- A stairway, ladder, ramp or other safe means of egress is located in trench

excavations that are four feet or more in depth so as to require no more than 25 feet

of lateral travel for employees.

- Backfilling and removal of support systems are performed only after employees have

cleared the area. All excavations shall be backfilled and graded promptly.

- Trenches greater than four feet deep shall require an approved confined space entry

permit.

The client requiring DEECO personnel to enter a trench or excavation shall provide training to

DEECO personnel in accordance to client and OSHA regulations and policies.

2.11 Floor/Wall Openings

With regards to guarding floor and wall openings and holes, workers will comply with 29 CFR

1910.23 and 1926, Subpart M.

General requirements are as follows:

1. Ladderway floor openings shall be guarded by a standard railing and toe-boards or cover.

In general, the railing shall be provided on all exposed sides, except at entrances to stairways.

2. Hatchways and chute floor openings shall be guarded by one of the following:

a. Hinged covers and a standard railing with only exposed side.

b. A removable standard railing with toe-board on not more than two sides and fixed

standard railings with toe boards on all other exposed sides.

3. Temporary floor openings, into which persons can accidentally walk, shall be guarded by

either a standard railing with toe-board on all exposed sides, or a floor hole cover that is

secured against accidental displacement.

4. Wall openings, from which there is a drop of more than four feet, and the bottom of the

opening is less than three feet above the working surface, shall be guarded as follows:

a. A standard rail, if that will effectively reduce the danger of falling. If the bottom of

a wall opening is less than four inches above the working surface, a toe-board or an

enclosing screen shall also be provided.

5. Every open-sided floor or platform four feet or more above adjacent floor or ground level

shall be guarded by a standard railing or equivalent. A toe-board shall be provided wherever,

beneath the open sides, persons can pass or there is moving machinery or there is equipment

with which falling material could create a hazard.
DEECO Health and Safety Plan Page 15 January 2010

Standard Specifications

1. A standard railing shall consist of top rail, intermediate rail, toe-board and posts, and shall

have a vertical height of approximately 42 inches.

a. The intermediate rail shall be halfway between the top rail and the floor, platform

runway or ramp.

b. Posts shall be spaced not more than eight feet on corners.

c. A completed railing structure shall be capable of withstanding a load of at least 200

pounds applied in any direction at any point on the top rail, with a minimum of

deflection.

2. A standard handrail shall be of a construction similar to a standard rail except that it is

mounted on a wall or partition and does not include an intermediate rail.

a. The height to handrails shall not be more than 34 inches or less than 30 inches from

top surface to tread or ramp.

b. Handrails and railings shall be provided with a clearance of approximately three

inches between the rail and any other object.

3. Floor opening covers shall be of any material that meets the following strength requirements:

a. The cover, when located in roadways or vehicular aisles, shall be designed to carry

a truck rear axle load of at least two times the maximum intended load.

b. The floor opening cover shall be capable of supporting the maximum intended load

and so installed as to prevent accidental displacement.

4. Wall opening protection shall meet the following requirements:

a. Barriers shall be of such construction and mounting that, when in place, they are

capable of withstanding a load of at least 200 pounds applied in any direction (except

upward) with a minimum deflection.

5. During the performance of work on low pitched roofs, employees shall be protected at all

open sides and edges by the use of a motion-stopping safety system.

Barricades

1. Signs, signals and barricades shall be posted to detour passage of persons and vehicles at

locations where potential hazards exist.

a. Barricades must be 42 inches high.

b. Barricades should be kept four feet back from the edge of excavations, holes, and

platforms and six feet back from the edge of low-pitched roofs.

c. Barricades with flashing lights shall be provided at night.
DEECO Health and Safety Plan Page 16 January 2010

2. All employees engaged in built-up roofing work will undergo training so that they are able

to recognize and deal with the hazards of falling associated the working near a roof

perimeter.

2.12 Hearing Conservation

DEECO personnel may be exposed to excessive noise levels while on a client's premises. The

project manager/field team leader will ensure all high noise areas have been identified, and that each

member of the field team is aware of the location of these areas. Hearing protection is to be provided

by DEECO to field personnel at no cost. Employees will wear hearing protection as instructed and

in all areas required.

Hearing Conservation Training Program

DEECO will train each employee who is exposed to noise at or above an 8-hour time weighted

average of 85 decibels. DEECO will institute a training program and ensure employee participation

in the program.

The training program will be repeated annually for each employee included in the hearing

conservation program. Information provided in the training program will be updated to be consistent

with changes in protective equipment and work processes.

DEECO will ensure that each employee is informed of the effects of noise on hearing, the purpose

of hearing protectors, the advantages, disadvantages, and attenuation of various types, and

instructions on selection, fitting, use, and care, and the purpose of audiometric testing and an

explanation of the audiometric test procedures.

DEECO will provide annual audiometric exams for all personnel. The President is responsible for

ensuring compliance with applicable regulations (29 CFR 1910.95, "Occupational Noise Exposure",

and 1926.101, "Hearing Protection"). 

Audiometric Testing Program

DEECO will establish and maintain an audiometric testing program by making audiometric testing

available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85

decibels. The program shall be provided at no cost to employees.

Audiometric tests will be be performed by a licensed or certified audiologist, otolaryngologist, or

other physician, or by a technician who is certified by the Council of Accreditation in Occupational

Hearing Conservation, or who has satisfactorily demonstrated competence in administering

audiometric examinations, obtaining valid audiograms, and properly using, maintaining and

checking calibration and proper functioning of the audiometers being used. A technician who

operates microprocessor audiometers does not need to be certified. A technician who performs

audiometric tests must be responsible to an audiologist, otolaryngologist or physician.

All audiograms obtained pursuant to this section shall meet the requirements of OSHA 1910,

Appendix C: "Audiometric Measuring Instruments."
DEECO Health and Safety Plan Page 17 January 2010

Baseline Audiogram

Within 6 months of an employee's first exposure at or above the action level, DEECO will establish

a valid baseline audiogram against which subsequent audiograms can be compared.

Where baseline audiograms are obtained more than 6 months after the employee's first exposure at

or above the action level, employees shall wear hearing protectors for any period exceeding six

months after first exposure until the baseline audiogram is obtained.

Testing to establish a baseline audiogram shall be preceded by at least 14 hours without exposure

to workplace noise. Hearing protectors may be used as a substitute for the requirement that baseline

audiograms be preceded by 14 hours without exposure to workplace noise. DEECO will notify

employees of the need to avoid high levels of non-occupational noise exposure during the 14-hour

period immediately preceding the audiometric examination.

Annual Audiogram

At least annually after obtaining the baseline audiogram, DEECO will obtain a new audiogram for

each employee exposed at or above an 8-hour time-weighted average of 85 decibels.

Evaluation of Audiogram

Each employee's annual audiogram will be compared to that employee's baseline audiogram to

determine if the audiogram is valid and if a standard threshold shift (as defined in OSHA

1910.95(g)(10)) has occurred. This comparison may be done by a technician.

If the annual audiogram shows that an employee has suffered a standard threshold shift, DEECO will

obtain a retest within 30 days and consider the results of the retest as the annual audiogram.

An audiologist, an otolaryngologist, or a physician will review problem audiograms and will

determine whether there is a need for further evaluation. DEECO will provide to the person

performing this evaluation, a copy of the requirements for hearing conservation as set forth in OSHA

1910.95 paragraphs (c) through (n), the baseline audiogram and most recent audiogram of the

employee to be evaluated, measurements of background sound pressure levels in the audiometric test

room as required in OSHA 1910Appendix D: Audiometric Test Rooms, and records of audiometer

calibrations required by OSHA 1910 paragraph (h)(5).

Follow-up Procedures

If a comparison of the annual audiogram to the baseline audiogram indicates a standard threshold

shift, the employee will be informed of this fact in writing, within 21 days of the determination.

Unless a physician determines that the standard threshold shift is not work related or aggravated by

occupational noise exposure, DEECO will ensure that the employees not using hearing protectors

will be fitted with hearing protectors, trained in their use and care, and required to use them.

Employees already using hearing protectors shall be refitted and retrained in the use of hearing

protectors and provided with hearing protectors offering greater attenuation if necessary.
DEECO Health and Safety Plan Page 18 January 2010

The employee will be referred for a clinical audiological evaluation or an otological examination,

as appropriate, if additional testing is necessary or if DEECO suspects that a medical pathology of

the ear is caused or aggravated by the wearing of hearing protectors.

The employee will be informed of the need for an otological examination if a medical pathology of

the ear that is unrelated to the use of hearing protectors is suspected.

If subsequent audiometric testing of an employee whose exposure to noise is less than an 8-hour

TWA of 90 decibels indicates that a standard threshold shift is not persistent, DEECO will inform

the employee of the new audiometric interpretation and mMay discontinue the required use of

hearing protectors for that employee.

Revised Baseline

An annual audiogram may be substituted for the baseline audiogram when, in the judgment of the

audiologist, otolaryngologist or physician who is evaluating the audiogram, that the standard

threshold shift revealed by the audiogram is persistent or the hearing threshold shown in the annual

audiogram indicates significant improvement over the baseline audiogram.

2.13 Housekeeping

Employees shall maintain a high standard of housekeeping on the job at all times as an integral part

of the work The purpose of this requirement is to ensure the safety of all personnel entering the lob

location and to maintain a condition of housekeeping that is consistent with the desired appearance

of a DEECO job location.

Project managers/field team leaders shall clean up work areas daily, store all equipment and

construction materials in an orderly manner in storage areas. Barricades shall be used for temporary

storage of equipment and construction materials. All scrap construction materials and waste shall

be picked up and disposed of at least daily. All location procedures for waste disposal shall be

followed. Form wood and other lumber shall be neatly stored when not in use. All nails shall be

removed or bent over to prevent puncture wounds.

All stairways, walkways, ladder cages and scaffolds shall be kept clear of all cords, cables, hosed,

materials and anything else that might hinder personnel access. Cords, cables and hosed at stairways,

walkways and scaffolds will be supported at least seven feet overhead or laid flat outside of

walkways.

All spills of oil, solvents, chemicals and any regulated liquids shall be reported to the site

representative immediately and shall be properly cleaned up and disposed of. Dumping of these

materials in floor drains, sanitary sewers, storm sewers. drainage ditches, or other open ground is

forbidden.

Employees shall be responsible for keeping all location roads free from all debris resulting from their

performance of the work. Storage of combustible and flammable materials shall not be located under

overhead pipelines and utilities. Loose materials on roofs or other overhead structures shall be

removed or secured to prevent being blown or bumped off. Accumulation of materials that may
DEECO Health and Safety Plan Page 19 January 2010

create a fire hazard shall not be permitted. Storage of materials shall be at least eight feet from the

center of railroad tracks.

Project managers/field team leaders shall perform a housekeeping review of the work site at the end

of each day. All concerns noted will be corrected prior to the field team leaving the site.

2.14 Manual Lifting

When lifting heavy objects, an improper lifting technique may result in a serious injury. When

lifting objects, ensure that you:

# Know your limitation. Enlist help before lifting objects that are beyond your

strength.

# Have cleared a path to carry the object, before lifting the object.

# Lift with your legs, keeping your back straight.

# Have a firm grip and a sure footing before lifting the object.

# Lift objects gradually. Avoid jerking motions and awkward positions.

# Avoid twisting your body when carrying the object. Turn your entire body with the

object.

2.15 Mechanical Lifting

Mechanical lifting aids, such as hoists, trucks, dollies, and jacks are to be used to assist Field

personnel in handling heavy objects. Field personnel must ensure that:

# The rated capacity of the mechanical device is not exceeded.

# When lifting objects to a higher work location, the area below the lifted object is kept

clear by restricting access using ropes, barricades, or other barriers.

# Loads are not left suspended in the air. Raise the load only when it can be unloaded

at its destination.

# Attempts are not made to catch or grab falling objects.

2.16 Mechanical and Electrical Safety

Analytical Equipment

The use and repair of analytical equipment can present unusual electrical and mechanical hazards.

Before performing work on any piece of equipment:

# Ensure that power has been disconnected from the unit.

# Ensure that any reserve power (capacitors, batteries) are de-energized before working

on unit.

# Do not remove any piece of equipment labelled "Trained Service Personnel Only".

Call the appropriate service organization for repair of the unit.

Additional mechanical and electrical hazards may exist. Employees must be aware of all hazards

before performing any repair work. Employees should consult the client's representative before

connecting transformers or other electrical lines to power supplies. See Lockout/Tagout procedures

in the Supplement of this manual.
DEECO Health and Safety Plan Page 20 January 2010

2.17 New Employee Orientation

All new employees will undergo initial safety training which includes assigned responsibilities, first

aid procedures (including bloodborne pathogens procedures), accident response and reporting

procedures, emergency action plan and spill procedures, fire protection, general safety rules, and

housekeeping. Subsequent safety training will be provided based on job description.

2.18 Power and Hand Tools

Improper use of power and hand tools can lead to serious injuries. Field personnel should be familiar

with the tools used and their operating manuals. Field personnel should ensure that:

# Tools are used for the propose for which they were designed.

# Power tools must be either grounded or double-insulated.

# Defective or damaged tools must be labelled and stored such that other employees

will not mistakenly use the tool.

# Safety glasses with side shields or goggles must be worn when using power tools that

may produce projectiles.

2.19 Process Safety Management

Many client locations will be required to provide DEECO (the contract employee) with process

safety management (PSM) information. The processes that require PSMs involves a flammable

liquid or gas (as defined in OSHA 1926.59(c)) on site in one location, in a quantity of 10,000 pounds

(4535.9 kg) or more except for hydrocarbon fuels used solely for workplace consumption as a fuel

(e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part

of a process containing another highly hazardous chemical covered by this standard and flammable

liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point

without benefit of chilling or refrigeration. PSM describes the procedures for preventing or

minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive

chemicals. These releases may result in toxic, fire or explosion hazards

The DEECO project manager/field team leader shall ensure that all DEECO employees understand

and follow these procedures.

Management of Change

DEECO work activities at client’s facility may impact on the operation of a PSM regulated process.

The DEECO project manager/field team leader and the client’s facility representative will perform

an initial process hazard analysis (hazard evaluation) on processes covered. The process hazard

analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control

the hazards involved in the process as they relate to DEECO’s work activities. The client’s facility

representative shall determine and document the priority order for conducting process hazard

analyses based on a rationale which includes such considerations as extent of the process hazards,

number of potentially affected employees, age of the process, and operating history of the process.

The process hazard analysis must be conducted before any work by DEECO is conducted.
DEECO Health and Safety Plan Page 21 January 2010

2.20 Scaffolding

Scaffold Erection and Inspection

It is DEECO’s policy not to erect scaffolding. Scaffolding is typically the responsibility of the

client. Scaffolds shall be designed by a qualified person and shall be constructed and loaded in

accordance with that design. Scaffolds shall be erected, moved, dismantled, or altered only under

the supervision and direction of a competent person qualified in scaffold erection, moving,

dismantling or alteration. Such activities shall be performed only by experienced and trained

employees selected for such work by the competent person.

Each day before using any scaffolding, ensure that the scaffolding has been inspected by a person

qualified in scaffold inspection. 

General Requirements for Scaffolding Use

1. The footing or anchorage for scaffolds shall be sound, rigid and capable of carrying the

maximum intended load without settling or displacement.

2. Guardrails and toe-boards shall be installed on all open sides and ends of scaffold platforms

more than four feet above the ground or floor.

3. Scaffolds shall be provided with an access ladder or equivalent safe access.

4. Employees shall not climb or work from scaffold handrails, mid-rails or brace members.

5. When free-standing manually propelled mobile scaffolds are used, the height shall not

exceed four times the minimum base dimension.

a.Employees shall not ride on mobile scaffolds when they are being moved.

6. All scaffolds shall be inspected by a competent person prior to use and shall be acceptancetagged.

7. Employees who erect scaffolds shall be trained in the proper means of building scaffolds.

8. Employees using scaffolds shall be trained in the safe use of scaffolds.

The project manager/field team leader must ensure that all scaffolding is erected in accordance with

OSHA regulations and the items listed above. 

The project manager/field team leader must check with client's representative to see if additional fall

protection is required when working on scaffolding.

Scaffold Use Training

DEECO shall have each employee who performs work while on a scaffold trained by a person

qualified in the subject matter to recognize the hazards associated with the type of scaffold being

used and to understand the procedures to control or minimize those hazards. The training shall

include the following areas, as applicable:

1. The nature of any electrical hazards, fall hazards and falling object hazards in the work area;

2. The correct procedures for dealing with electrical hazards and for erecting, maintaining, and

disassembling the fall protection systems and falling object protection systems being used;
DEECO Health and Safety Plan Page 22 January 2010

3. The proper use of the scaffold, and the proper handling of materials on the scaffold; and

4. The maximum intended load and the load-carrying capacities of the scaffolds used.

Additional training will be provided when changes in the types of scaffolds, fall protection, falling

object protection, or other equipment present a hazard about which an employee has not been

previously trained or when inadequacies in an affected employee's work involving scaffolds indicate

that the employee has not retained the requisite proficiency.

2.21 Stairways and Ladders

With regards to stairways and ladders, employees should follow 29 CFR 1910.25, 26, and 27,

"Portable Wood Ladders, "Portable Metal Ladders, and Fixed Ladders", and 1926 Subpart X,

"Stairways and Ladders".

General Requirements

1. A stairway or ladder shall be provided at all personnel points of access where there is a break

in elevation of 19 inches or more, and no ramp, runway, sloped embankment or personnel

hoist is provided.

2. A double-cleated ladder or two or more separate ladders shall be provided when ladders are

the only means of access or egress from a working area for 25 or more employees, or when

the ladder is to serve simultaneous two-way traffic.

3. When a building or structure has only one point of access between levels, that point of access

shall be kept clear to permit free passage of employees.

Stairways

1. Stairways that will not be a permanent part of the structure on which construction work is

being performed shall have landings of not less than 30 inches in the direction of travel and

extend at least 22 inches in width at every 12 feet or less of vertical rise.

2. Riser height and tread depth shall be uniform within each flight of stairs.

3. Where doors or gates open directly on a stairway, a platform shall be provided, and the swing

of the door shall not reduce the effective width of the platform to less than 20 inches.

4. Slippery conditions on stairways shall be eliminated before the stairways are used to reach

other levels.

5. Except during stairway construction, foot traffic shall be prohibited on skeleton metal stairs

where the treads and landings are to be filled in at a later date, unless the stairs are fitted with

secured temporary treads and landings long enough to cover the entire tread and landing area.

6. Stairways having four or more risers or rising more than 30 inches, whichever is less, shall

be equipped with at least one handrail and one system along each unprotected side or edge.

7. Stairrails shall be not less than 36 inches from the upper surface of the strairrail system to the

surface of the tread.

8. Mid-rails, screens, mesh, intermediate vertical members, or equivalent intermediate structural

members, shall be provided between the top rail of the stairrail system and the stair\way

steps.
DEECO Health and Safety Plan Page 23 January 2010

9. Handrails and the top rails of stairrail systems shall be capable of withstanding a force of at

least 200 pounds applied within two inches of the top edge, in any downward or outward

direction, at any point along the top edge.

10. Fixed stairways shall conform to the requirements of 29 CFR 1919.24 "Fixed Industrial

Stairs".

Ladders

1. Portable ladders shall be capable of supporting at least four times the maximum intended

load.

2. Portable metal or conductive ladders shall not be used near energized lines or equipment

except as may be necessary in specialized work such as high voltage substations where nonconductive ladders might present a greater hazard than conductive ladders. Conductive or

metal ladders shall be prominently marked a conductive and all necessary precautions shall

be taken when used in specialized work.

3. Ladder rungs, cleats and steps shall be parallel, level and uniformly spaced when the ladder

is in position for use.

4. The minimum clear distance between side rails for all portable ladders shall be 11.5 inches.

5. The following requirements apply to the use of all ladders, including job-made ladders.

a. Ladders used for access to an upper landing surface, shall have side rails that extend

at least three feet above the landing surface.

b. Ladders shall be maintained free of oil, grease and other slipping hazards.

c. Ladders shall be used only for the purpose for which they were designed.

d. Non-self-supporting ladders shall be used at an angle such that the horizontal

distance from the top support to the foot of the ladder is approximately one-quarter

of the working length of the ladder.

e. Non-self-supporting ladders shall be tied off or otherwise secured to prevent

accidental displacement.

f. When ascending or descending a ladder, the user shall face the ladder and shall use

at least one hand to grasp the ladder. The user shall not carry any object or load that

could cause him/her to lose balance and fall.

6. Ladders with structural defects, such as broken or missing rungs, shall be tagged DO NOT

USE, and shall be withdrawn from service.

7. Ladders will be inspected by a competent person and approved for use before being put into

service. Each user shall visually inspect ladder before using.

8. Ladders placed in any location where they can be displaced by workplace activities or traffic,

shall have warning signs posted.

Extension Ladders

1. After the extension section has been raised to desired height, the safety latches must be

engaged and the extension rope secured to a rung on the base section of the ladder before use.

2. Extension ladder sections are not to be used separately.

Stepladders

1. Must be set level on all four feet, with spreaders locked on place. Do not use as a straight

ladder.
DEECO Health and Safety Plan Page 24 January 2010

2. When used close to the edge of an elevated platform, roof or floor opening, and when

location requirements so specify, they must be tied off, and employees using such a

stepladder shall wear fall-arresting equipment.

3. Employees using stepladders shall stand so that their waists are below the top of the ladder.

The President shall ensure that all employees are trained in the proper use of ladders. 

2.22 Travel Safety

When driving any DEECO vehicle, or when driving your own personal vehicle when performing

DEECO related work, employees must:

# Obey all traffic rules and regulations.

# Obey all traffic rules on a plant site.

# Turn off vehicle and set brake when leaving vehicle.

# Use horn at blind driveways or intersections with an obstructive view.

# Have a valid North Carolina license to operate a DEECO vehicle and trailer.

# Never pick up hitchhikers.

# Perform a pre-trip check of vehicle(s) lights, horns, brakes, oil, etc.

2.23 Thermal Stress

Thermal stress to the body can be caused when the body temperature is not in balance between body

heat production and heat loss to the surrounding environment. Heat stress is caused when the body

is unable to sufficiently cool the body, and cold stress is possible when the body is unable to

sufficiently heat the body.

Heat Stress

Heat stress is a general term used to describe various degrees of heat illness. The temperature of the

body is a function of the amount of heat it produces and the amount of heat it can lose. When the

temperature of the environment approaches the body temperature, it becomes increasingly difficult

for the body to lose heat. Heat illness is possible when the body is not able to sufficiently cool itself.

The body can lose heat to the environment by three mechanisms. The most important is convection.

This is when the temperature of the skin is higher than that of the surrounding atmosphere.

Conduction is the transfer of heat from the body to a solid or liquid. An example would be the

immediate cooling of your face on a hot day by splashing cold water on it. Both convection and

conduction can also be negative, meaning that if the atmosphere or material in contact with the body

is warmer than the body itself, heat can be transferred to the body.

The third, and comparably small, mechanism is respiration. This is the warming and saturation of

respired air while in the lungs.

Effects of Heat

The body possesses two physiological responses which enable it to lose heat. The first is the dilation

(enlargement) of the blood vessels near the skin surface. This increases the flow of blood,

transferring heat to the skin. The skin temperature will increase, and is cooled by either convection

on conduction.
DEECO Health and Safety Plan Page 25 January 2010

The second response is sweating. Sweating occurs when the increase in blood flow to the skin does

not achieve the desired cooling effect. Heat is lost when sweat is evaporated from the body.

Heat Illness

Heat illness can be caused by either elevated body or skin temperatures. Elevated body temperatures

can result in heat exhaustion, heat cramps, and heat stroke. Elevated skin temperatures can cause

skin-tissue damage.

Heat Exhaustion

Heat exhaustion is caused by circulatory failure, where the amount of blood returned to the heart is

significantly reduced. Symptoms of heat exhaustion are fatigue, headache, dizziness, loss of

appetite, nausea, abdominal pain, vomiting, shortness of breath, and pulse rates in excess of 150

beats per minute. Heat exhaustion can result in poor judgement, irritability, and possibly fainting.

A person suffering from heat exhaustion can usually recover very quickly if he/she is removed to a

cool place and allowed to lie down.

Heat Cramps 

Heat cramps are muscle spasms which usually occur in the arms, legs, back and abdomen. This is

due to excessive loss of salt from sweating. Heat cramps can be prevented by taking extra salt when

heavy work is carried out. It is recommended that employees do not take salt tablets, but rather

ensure that they eat at regular intervals during the course of the work, Extra salt can by added to the

body through eating.

Heat Stroke

The most serious heat illness is heat stroke. When the body temperature reaches a certain level,

sweating may stop. This will cause the body temperature to increase to critical levels. Such an

increase in body temperature can cause denaturization of proteins, enzyme degradation, changes in

the viscosity of cell protoplasm, and alterations in the physical structure of the cell membranes.

Tissue damage and death are possible.

Immediate medical attention is necessary for individuals suffering from heat stroke in order to avoid

irreversible damage to the brain. The individual should be wrapped in cool, wet sheets. Immersion

in a cold bath is not recommended, since a too rapid decrease in the body temperature may result in

tissue damage.

Precautions

1. Water intake must equal the amount of water lost due to sweating and excretion. In hot

environments, water intake must be forced since the body's normal thirst mechanism is not

adequate to force the individual to drink. Continuous sweat rates of 1 to 2 liters per hours

are not unusual.

2. Salt is lost during sweating. Additions of small amounts of salt to food may be necessary.

3. Most importantly, frequent, short breaks during strenuous activities allows the body to better

adapt to the hot environment than infrequent long breaks. By taking shorter breaks, there is

less cumulative fatigue and less demand on the heart and respiration.

4. It is possible for the body to acclimatize to hot environments. This may happen only if

successive days are spent in the hot environment (usually between 4 to 7). 
DEECO Health and Safety Plan Page 26 January 2010

Cold Stress

In cold environments, the body must increase its metabolic heat production. In general, -30 EF is

the lower limit for prolonged work. Unlike hot environments, individuals do not acclimatize

(physiologically adapt) to cold environments.

The wind-chill temperature, rather than the ambient temperature, best describe a cold environment.

Wind velocity adds to the rate of body cooling.

Cold Illness

Hypothermia

Hypothermia is a general cooling of the body temperature. Hypothermia can occur in environments

above 32 EF. Symptoms include excessive shivering, and numbness in extremities. The individual

should be moved to a warm environment. Alcohol should not be consumed, since this will cause

the blood vessel to dilate, resulting in excessive body heat loss. Hot, non-alcoholic beverages should

be administered.

Frost Bite

Frost bite can be either superficial or can penetrate below the skin. Superficial frost bite can be

easily treated by warming the exposed skin with hands or other warmer part of the body (e.g. placing

hands under armpits). This will gradually warm the skin. Rapid warming (exposure to fire, soaking

in cold water etc.) is not recommended since damage to the skin tissue can occur. It is important to

note that pain will occur as the skin is thawed.

When frost bite extends below the surface of the skin (from prolonged exposure), it is essential to

get immediate medical attention.

Precautions

1. Individuals should eat balanced meals and replace body liquids regularly. Dehydration is as

prevalent in cold environments as it is in hot environments. Warm liquids are preferable

since they do not have to be warmed by the body after being consumed.

2. Proper protective clothing should be worn when exposed to cold environments. 

3 Dexterity and judgement are both diminished in cold environments.

2.24 Welding and Cutting

DEECO employees shall not perform any welding or cutting on a project site. The project

manager/field team leader shall ensure that the client contracts such work with qualified individuals.

DEECO employees shall leave the immediate area during any welding or cutting operations.

2.26 Lockout/Tagout (LOTO)

Lockout/Tagout (LOTO) refers to specific practices and procedures to safeguard employees from

the unexpected energization or startup of machinery and equipment, or the release of hazardous

energy during service or maintenance activities. Under no circumstance should DEECO

employee’s participate in LOTO. Should any LOTO be necessary at a client’s facility, all LOTO

procedures are to be handled by the client or their representative.
DEECO Health and Safety Plan Page 27 January 2010

2.27 Fall Protection

2.27.1 Determining When Fall Protection Must be Provided

DEECO shall determine if the walking/working surfaces on which its employees are to work have

the strength and structural integrity to support employees safely. Employees shall be allowed to work

on those surfaces only when the surfaces have the requisite strength and structural integrity.

Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected

side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by

the use of guardrail systems, safety net systems, or personal fall arrest systems.

Hoist Areas

Each employee in a hoist area shall be protected from falling 6 feet (1.8 m) or more to lower levels

by guardrail systems or personal fall arrest systems. If guardrail systems, [or chain, gate, or guardrail]

or portions thereof, are removed to facilitate the hoisting operation (e.g., during landing of

materials), and an employee must lean through the access opening or out over the edge of the access

opening (to receive or guide equipment and materials, for example), that employee shall be protected

from fall hazards by a personal fall arrest system.

Holes

Each employee on walking/working surfaces shall be protected from falling through holes (including

skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or

guardrail systems erected around such holes.

Each employee on a walking/working surface shall be protected from tripping in or stepping into or

through holes (including skylights) by covers.

Each employee on a walking/working surface shall be protected from objects falling through holes

(including skylights) by covers.

Formwork and Reinforcing Steel

Each employee working on the face of formwork or reinforcing steel shall be protected from falling

6 feet (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or

positioning device systems.

Ramps, Runways, and Other Walkways

Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8

m) or more to lower levels by guardrail systems.
DEECO Health and Safety Plan Page 28 January 2010

Excavations

Each employee at the edge of an excavation 6 feet (1.8 m) or more in depth shall be protected from

falling by guardrail systems, fences, or barricades when the excavations are not readily seen because

of plant growth or other visual barrier.

Each employee at the edge of a well, pit, shaft, and similar excavation 6 feet (1.8 m) or more in depth

shall be protected from falling by guardrail systems, fences, barricades, or covers.

Dangerous Equipment

Each employee less than 6 feet (1.8 m) above dangerous equipment shall be protected from falling

into or onto the dangerous equipment by guardrail systems or by equipment guards.

Each employee 6 feet (1.8 m) or more above dangerous equipment shall be protected from fall

hazards by guardrail systems, personal fall arrest systems, or safety net systems.

Overhand Bricklaying and Related Work

Currently, DEECO does not perform overhand bricklaying, so any fall protection programs related

to overhand brick are not applicable.

Working on Roofs

Each employee engaged in any activities on low-slope roofs (slope less than 4 in 12), with

unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling

by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning

line system and guardrail system, warning line system and safety net system, or warning line system

and personal fall arrest system, or warning line system and safety monitoring system.

Each employee on a steep roof (slope greater than 4 in 12) with unprotected sides and edges 6 feet

(1.8 m) or more above lower levels shall be protected from falling by guardrail systems with

toeboards, safety net systems, or personal fall arrest systems.

Precast Concrete Erection

Currently, DEECO does not perform precast concrete erection, so any fall protection programs

related to precast concrete erection are not applicable.

Residential Construction

Currently, DEECO does not perform residential construction, so any fall protection programs related

to residential construction are not applicable.
DEECO Health and Safety Plan Page 29 January 2010

Wall Openings

Each employee working on, at, above, or near wall openings (including those with chutes attached)

where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and

the inside bottom edge of the wall opening is less than 39 inches (1.0 m) above the walking/working

surface, shall be protected from falling by the use of a guardrail system, a safety net system, or a

personal fall arrest system.

Walking/Working Surfaces Not Otherwise Addressed (e.g Man Lifts)

When operating or working on any man lifts that fall under the ANSI standard definition that

includes certain vehicle-mounted elevating and rotating work platforms, namely "extensible boom

platforms," "aerial ladders," "articulating boom platforms," "vertical towers," and "a combination

of any of the above.", DEECO employees shall be protected from falling by a personal fall arrest

system.

For all other walking/working surfaces not otherwise addressed, each employee on a

walking/working surface 6 feet (1.8 m) or more above lower levels shall be protected from falling

by a guardrail system, safety net system, or personal fall arrest system.

Protection from Falling Objects

When an employee is exposed to falling objects, the employer shall have each employee wear a hard

hat and shall erect toeboards, screens, or guardrail systems to prevent objects from falling from

higher levels, erect a canopy structure and keep potential fall objects far enough from the edge of the

higher level so that those objects would not go over the edge if they were accidentally displaced; or,

barricade the area to which objects could fall, prohibit employees from entering the barricaded area,

and keep objects that may fall far enough away from the edge of a higher level so that those objects

would not go over the edge if they were accidentally displaced.

The project manager/field team leader must check with client's representative to see if additional

barricade procedures specific to their facility are required.

2.27.2 Guidelines for Fall Protection

The DEECO project manager/field team in conjunction with the client's representative shall

determine when additional fall protection is required.

The client shall provide and install all Guard Rail Systems, Safety Net Systems, Positioning Device

Systems and Warning Line Systems required for DEECO an employee, and shall comply with all

other pertinent requirements of described below before that employee begins the work that

necessitates the fall protection.

Guardrail Systems 

Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus

or minus 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of
DEECO Health and Safety Plan Page 30 January 2010

the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria

of this paragraph.

Note: When employees are using stilts, the top edge height of the top rail, or equivalent member,

shall be increased an amount equal to the height of the stilts.

Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural

members shall be installed between the top edge of the guardrail system and the walking/working

surface when there is no wall or parapet wall at least 21 inches (53 cm) high.

Midrails, when used, shall be installed at a height midway between the top edge of the guardrail

system and the walking/working level.

Screens and mesh, when used, shall extend from the top rail to the walking/working level and along

the entire opening between top rail supports.

Intermediate members (such as balusters), when used between posts, shall be not more than 19

inches (48 cm) apart.

Other structural members (such as additional midrails and architectural panels) shall be installed

such that there are no openings in the guardrail system that are more than 19 inches (.5 m) wide.

Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds

(890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at

any point along the top edge.

When the 200 pound (890 N) test load specified above is applied in a downward direction, the top

edge of the guardrail shall not deflect to a height less than 39 inches (1.0 m) above the

walking/working level.

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural

members shall be capable of withstanding, without failure, a force of at least 150 pounds (666 N)

applied in any downward or outward direction at any point along the midrail or other member.

Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or

lacerations, and to prevent snagging of clothing.

The ends of all top rails and midrails shall not overhang the terminal posts, except where such

overhang does not constitute a projection hazard.

Steel banding and plastic banding shall not be used as top rails or midrails.

Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diameter or thickness to

prevent cuts and lacerations. If wire rope is used for top rails, it shall be flagged at not more than 6-

foot intervals with high-visibility material.

When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall

be placed across the access opening between guardrail sections when hoisting operations are not

taking place.
DEECO Health and Safety Plan Page 31 January 2010

When guardrail systems are used at holes, they shall be erected on all unprotected sides or edges of

the hole.

When guardrail systems are used around holes used for the passage of materials, the hole shall have

not more than two sides provided with removable guardrail sections to allow the passage of

materials. When the hole is not in use, it shall be closed over with a cover, or a guardrail system shall

be provided along all unprotected sides or edges.

When guardrail systems are used around holes which are used as points of access (such as

ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into

the hole.

Guardrail systems used on ramps and runways shall be erected along each unprotected side or edge.

Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected as frequently

as necessary to ensure that it continues to meet the strength requirements of paragraph (b)(3) of this

section.

Safety Net Systems

Safety nets shall be installed as close as practicable under the walking/working surface on which

employees are working, but in no case more than 30 feet (9.1 m) below such level. When nets are

used on bridges, the potential fall area from the walking/working surface to the net shall be

unobstructed.

Safety nets shall extend outward from the outermost projection of the work surface as follows:

Vertical distance from working level to

horizontal plane of net

Minimum required horizontal distance of

outer edge of net from the edge of the

working surface

Up to 5 feet 8 feet

More than 5 feet up to 10 feet 10 feet

More than 10 feet 13 feet

Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface

or structures below when subjected to an impact force equal to the drop test described below. Safety

nets and their installations shall be capable of absorbing an impact force equal to that produced by

the drop test described below.

Except as described below, safety nets and safety net installations shall be drop-tested at the jobsite

after initial installation and before being used as a fall protection system, whenever relocated, after

major repair, and at 6-month intervals if left in one place. The drop-test shall consist of a 400 pound

(180 kg) bag of sand 30 + or - 2 inches (76 + or - 5 cm) in diameter dropped into the net from the

highest walking/working surface at which employees are exposed to fall hazards, but not from less

than 42 inches (1.1 m) above that level.
DEECO Health and Safety Plan Page 32 January 2010

When the employer can demonstrate that it is unreasonable to perform the drop-test, the employer

(or a designated competent person) shall certify that the net and net installation is in compliance with

the provisions of paragraphs (c)(3) and (c)(4)(i) of this section by preparing a certification record

prior to the net being used as a fall protection system. The certification record must include an

identification of the net and net installation for which the certification record is being prepared; the

date that it was determined that the identified net and net installation were in compliance with

paragraph (c)(3) of this section and the signature of the person making the determination and

certification. The most recent certification record for each net and net installation shall be available

at the jobsite for inspection.

Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear,

damage, and other deterioration. Defective components shall be removed from service. Safety nets

shall also be inspected after any occurrence which could affect the integrity of the safety net system.

Materials, scrap pieces, equipment, and tools which have fallen into the safety net shall be removed

as soon as possible from the net and at least before the next work shift.

The maximum size of each safety net mesh opening shall not exceed 36 square inches (230 cm) nor

be longer than 6 inches (15 cm) on any side, and the opening, measured center-to-center of mesh

ropes or webbing, shall not be longer than 6 inches (15 cm). All mesh crossings shall be secured to

prevent enlargement of the mesh opening.

Each safety net (or section of it) shall have a border rope for webbing with a minimum breaking

strength of 5,000 pounds (22.2 kN).

Connections between safety net panels shall be as strong as integral net components and shall be

spaced not more than 6 inches (15 cm) apart.

Personal Fall Arrest Systems

Personal fall arrest systems shall consist of a full body harness. Body belts are not acceptable as part

of a personal fall arrest system except in a positioning device system as described below.

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall

have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to

interfacing parts of the system.

Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds (22.2 kN) and shall

be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or

taking permanent deformation.

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent

unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected

member, or shall be a locking type snaphook designed and used to prevent disengagement of the

snaphook by the contact of the snaphook keeper by the connected member. Only locking type

snaphooks shall be used.
DEECO Health and Safety Plan Page 33 January 2010

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall

not be engaged directly to webbing, rope or wire rope, to each other, to a dee-ring to which another

snaphook or other connector is attached, to a horizontal lifeline; or to any object which is

incompatibly shaped or dimensioned in relation to the snaphook such that unintentional

disengagement could occur by the connected object being able to depress the snaphook keeper and

release itself.

On suspended scaffolds or similar work platforms with horizontal lifelines which may become

vertical lifelines, the devices used to connect to a horizontal lifeline shall be capable of locking in

both directions on the lifeline. Horizontal lifelines shall be designed, installed, and used, under the

supervision of a qualified person, as part of a complete personal fall arrest system, which maintains

a safety factor of at least two.

Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds (22.2 kN).

Lifelines shall be protected against being cut or abraded. Self-retracting lifelines and lanyards which

automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a

minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanyard

in the fully extended position.

Self-retracting lifelines and lanyards which do not limit free fall distance to 2 feet (0.61 m) or less,

ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum

tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully

extended position.

Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and

body harnesses shall be made from synthetic fibers.

Anchorages used for attachment of personal fall arrest equipment shall be independent of any

anchorage being used to support or suspend platforms and capable of supporting at least 5,000

pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as part of a

complete personal fall arrest system which maintains a safety factor of at least two and under the

supervision of a qualified person.

Personal fall arrest systems, when stopping a fall, shall limit maximum arresting force on an

employee to 900 pounds (4 kN) when used with a body belt, limit maximum arresting force on an

employee to 1,800 pounds (8 kN) when used with a body harness, be rigged such that an employee

can neither free fall more than 6 feet (1.8 m), nor contact any lower level, bring an employee to a

complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m)

and, have sufficient strength to withstand twice the potential impact energy of an employee free

falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is

less.

The attachment point of the body belt shall be located in the center of the wearer's back. The

attachment point of the body harness shall be located in the center of the wearer's back near shoulder

level, or above the wearer's head.

Body belts, harnesses, and components shall be used only for employee protection (as part of a

personal fall arrest system or positioning device system) and not to hoist materials.
DEECO Health and Safety Plan Page 34 January 2010

Personal fall arrest systems and components subjected to impact loading shall be immediately

removed from service and shall not be used again for employee protection until inspected and

determined by a competent person to be undamaged and suitable for reuse.

The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that

employees are able to rescue themselves.

Personal fall arrest systems shall be inspected prior to each use for wear, damage and other

deterioration, and defective components shall be removed from service.

Body belts shall be at least one and five-eighths (1 5/8) inches (4.1 cm) wide.

Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to

hoists. When a personal fall arrest system is used at hoist areas, it shall be rigged to allow the

movement of the employee only as far as the edge of the walking/working surface.

Positioning Device Systems

Positioning device systems shall be rigged such that an employee cannot free fall more than 2 feet

(.9 m). Positioning devices shall be secured to an anchorage capable of supporting at least twice the

potential impact load of an employee's fall or 3,000 pounds (13.3 kN), whichever is greater.

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall

have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to

interfacing parts of this system. Connecting assemblies shall have a minimum tensile strength of

5,000 pounds (22.2 kN).

Dee-rings and snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN)

without cracking, breaking, or taking permanent deformation. 

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent

unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected

member, or shall be a locking type snaphook designed and used to prevent disengagement of the

snaphook by the contact of the snaphook keeper by the connected member. As of January 1, 1998,

only locking type snaphooks shall be used.

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall

not be engaged directly to webbing, rope or wire rope, to each other, to a dee-ring to which another

snaphook or other connector is attached, to a horizontal lifeline; or to any object which is

incompatibly shaped or dimensioned in relation to the snaphook such that unintentional

disengagement could occur by the connected object being able to depress the snaphook keeper and

release itself.

Positioning device systems shall be inspected prior to each use for wear, damage, and other

deterioration, and defective components shall be removed from service.

Body belts, harnesses, and components shall be used only for employee protection (as part of a

personal fall arrest system or positioning device system) and not to hoist materials.
DEECO Health and Safety Plan Page 35 January 2010

Warning Line Systems

Warning line systems shall be erected around all sides of the roof work area. When mechanical

equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the

roof edge. When mechanical equipment is being used, the warning line shall be erected not less than

6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment

operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction

of mechanical equipment operation.

Points of access, materials handling areas, storage areas, and hoisting areas shall be connected to the

work area by an access path formed by two warning lines. When the path to a point of access is not

in use, a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line,

shall be placed across the path at the point where the path intersects the warning line erected around

the work area, or the path shall be offset such that a person cannot walk directly into the work area.

Warning lines shall consist of ropes, wires, or chains, and supporting stanchions erected as follows:

1. The rope, wire, or chain shall be flagged at not more than 6-foot (1.8 m) intervals with highvisibility material;

2. The rope, wire, or chain shall be rigged and supported in such a way that its lowest point

(including sag) is no less than 34 inches (.9 m) from the walking/working surface and its

highest point is no more than 39 inches (1.0 m) from the walking/working surface;

3. After being erected, with the rope, wire, or chain attached, stanchions shall be capable of

resisting, without tipping over, a force of at least 16 pounds (71 N) applied horizontally

against the stanchion, 30 inches (.8 m) above the walking/working surface, perpendicular to

the warning line, and in the direction of the floor, roof, or platform edge;

4. The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and

after being attached to the stanchions, shall be capable of supporting, without breaking, the

loads applied to the stanchions as described above; and

5. The line shall be attached at each stanchion in such a way that pulling on one section of the

line between stanchions will not result in slack being taken up in adjacent sections before the

stanchion tips over.

No employee shall be allowed in the area between a roof edge and a warning line unless the

employee is performing roofing work in that area.

Mechanical equipment on roofs shall be used or stored only in areas where employees are protected

by a warning line system, guardrail system, or personal fall arrest system.

Controlled Access Zone

When used to control access to areas where leading edge and other operations are taking place the

controlled access zone shall be defined by a control line or by any other means that restricts access.
DEECO Health and Safety Plan Page 36 January 2010

When control lines are used, they shall be erected not less than 6 feet (1.8 m) nor more than 25 feet

(7.7 m) from the unprotected or leading edge, except when erecting precast concrete members.

DEECO does not erecting precast concrete members. The control line shall extend along the entire

length of the unprotected or leading edge and shall be approximately parallel to the unprotected or

leading edge. The control line shall be connected on each side to a guardrail system or wall.

Additional control lines shall be erected at each end to enclose the controlled access zone.

Control lines shall consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions.

Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with

high-visibility material. Each line shall be rigged and supported in such a way that its lowest point

(including sag) is not less than 39 inches (1 m) from the walking/working surface and its highest

point is not more than 45 inches (1.3 m) from the walking/working surface. Each line shall have a

minimum breaking strength of 200 pounds (.88 kN).

Safety Monitoring Systems

DEECO shall designate a competent person as the safety monitor. The safety monitor will monitor

the safety of other employees. The safety monitor shall be competent to recognize fall hazards. The

safety monitor shall warn the employee when it appears that the employee is unaware of a fall hazard

or is acting in an unsafe manner. The safety monitor shall be on the same walking/working surface

and within visual sighting distance of the employee being monitored. The safety monitor shall be

close enough to communicate orally with the employee. The safety monitor shall not have other

responsibilities which could take the monitor's attention from the monitoring function.

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being

used to monitor employees engaged in roofing operations on low-slope roofs. No employee, other

than an employee engaged in roofing work [on low-sloped roofs] or an employee covered by a fall

protection plan, shall be allowed in an area where an employee is being protected by a safety

monitoring system.

Each employee working in a controlled access zone shall be directed to comply promptly with fall

hazard warnings from safety monitors.

Covers

Covers located in roadways and vehicular aisles shall be capable of supporting, without failure, at

least twice the maximum axle load of the largest vehicle expected to cross over the cover. All other

covers shall be capable of supporting, without failure, at least twice the weight of employees,

equipment, and materials that may be imposed on the cover at any one time. All covers shall be

secured when installed so as to prevent accidental displacement by the wind, equipment, or

employees. All covers shall be color coded or they shall be marked with the word "HOLE" or

"COVER" to provide warning of the hazard.

Protection from Falling Objects

Toeboards, when used as falling object protection, shall be erected along the edge of the overhead

walking/working surface for a distance sufficient to protect employees below. Toeboards shall be
DEECO Health and Safety Plan Page 37 January 2010

capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any

downward or outward direction at any point along the toeboard. Toeboards shall be a minimum of

3 1/2 inches (9 cm) in vertical height from their top edge to the level of the walking/working surface.

They shall have not more than 1/4 inch (0.6 cm) clearance above the walking/working surface. They

shall be solid or have openings not over 1 inch (2.5 cm) in greatest dimension. Where tools,

equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall

be erected from the walking/working surface or toeboard to the top of a guardrail system's top rail

or midrail, for a distance sufficient to protect employees below. Guardrail systems, when used as

falling object protection, shall have all openings small enough to prevent passage of potential falling

objects.

Canopies, when used as falling object protection, shall be strong enough to prevent collapse and to

prevent penetration by any objects which may fall onto the canopy.

Fall Protection Plan

This option is available only to employees engaged in leading edge work that it is infeasible or it

creates a greater hazard to use conventional fall protection equipment. 

The fall protection plan shall be prepared by a qualified person and developed specifically for the

site where the leading edge work, precast concrete work, or residential construction work is being

performed and the plan must be maintained up to date. Any changes to the fall protection plan shall

be approved by a qualified person. A copy of the fall protection plan with all approved changes shall

be maintained at the job site. The implementation of the fall protection plan shall be under the

supervision of a competent person. The fall protection plan shall document the reasons why the use

of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets

systems) are infeasible or why their use would create a greater hazard.

The fall protection plan shall include a written discussion of other measures that will be taken to

reduce or eliminate the fall hazard for workers who cannot be provided with protection from the

conventional fall protection systems. For example, the employer shall discuss the extent to which

scaffolds, ladders, or vehicle mounted work platforms can be used to provide a safer working surface

and thereby reduce the hazard of falling.

The fall protection plan shall identify each location where conventional fall protection methods

cannot be used. These locations shall then be classified as controlled access zones. Where no other

alternative measure has been implemented, the employer shall implement a safety monitoring

system.

The fall protection plan must include a statement which provides the name or other method of

identification for each employee who is designated to work in controlled access zones. No other

employees may enter controlled access zones.

In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the

employer shall investigate the circumstances of the fall or other incident to determine if the fall

protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement

those changes to prevent similar types of falls or incidents.
DEECO Health and Safety Plan Page 38 January 2010

2.27.3 Fall Protection Training Program

DEECO shall provide a training program for each employee who might be exposed to fall hazards.

The program shall enable each employee to recognize the hazards of falling and shall train each

employee in the procedures to be followed in order to minimize these hazards.

DEECO shall assure that each employee has been trained, as necessary, by a competent person

qualified in the nature of fall hazards in the work area, the correct procedures for erecting,

maintaining, disassembling, and inspecting the fall protection systems to be used, the use and

operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems,

safety monitoring systems, controlled access zones, and other protection to be used, the role of each

employee in the safety monitoring system when this system is used, the limitations on the use of

mechanical equipment during the performance of roofing work on low-sloped roofs, the correct

procedures for the handling and storage of equipment and materials and the erection of overhead

protection; and the role of employees in fall protection plans.

Certification of Training

DEECO shall verify compliance with the Fall Protection Training Program by preparing a written

certification record. The written certification record shall contain the name or other identity of the

employee trained, the date(s) of the training, and the signature of the person who conducted the

training or the signature of the employer. If training is conducted by another employer, the

certification record shall indicate the date the employer determined the prior training was adequate

rather than the date of actual training.

The latest training certification shall be maintained.

Retraining

When DEECO has reason to believe that any affected employee who has already been trained does

not have the understanding and skill required by the Fall Protection Training Program, DEECO shall

retrain each such employee. Circumstances where retraining is required include, but are not limited

to, situations where changes in the workplace render previous training obsolete, changes in the types

of fall protection systems or equipment to be used render previous training obsolete, or inadequacies

in an affected employee's knowledge or use of fall protection systems or equipment indicate that the

employee has not retained the requisite understanding or skill.

2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen

Monitors 

For safe operation around processes involving combustible materials, a hot work permit may be

required. Hot work permits (HWPs) are required for any process where testing activities may

produce an ignition source in a work area in which flammable vapors or gases may be present. To

issue an HWP, a hazard assessment must be performed. To do so, combustible gas and vapor

concentrations must be determined for the work area and job classification in question, then

compared to acceptable standards. These surveys typically involve the use of combustible gas

meters-also called lower explosive limit (LEL) meters. These surveys are conducted by the client

personnel issuing the hot work permits .
DEECO Health and Safety Plan Page 39 January 2010

To perform the surveys properly, the facility will have work instructions and standard operating

procedures (SOPs) developed, implemented and documented. Training in LEL instrument use,

instrument calibration, sampling strategy, continuous or follow-up monitoring, tracking of denied

permits, communication between departments related to the content of processes, documentation of

results, auditing of hot work permit procedures and results, and the continuous improvement of those

SOPs will be addressed. 

In some cases DEECO will be required to provide additional monitoring for LEL, carbon monoxide,

hydrogen sulfide, and/or oxygen. For these situations, DEECO personnel will be trained in LEL,

carbon monoxide, hydrogen sulfide, and/or oxygen instrument use and instrument calibration.

Training in Instrument Use

Thorough, documented training will be performed for the use of LEL, carbon monoxide, hydrogen

sulfide, and/or oxygen meters. Thus, training programs for operators of LEL, carbon monoxide,

hydrogen sulfide, and/or oxygen meters will include:

1. Work instructions for basic instrument use;

2. Theory of instrument operation;

3 Instrument maintenance and calibration; and 

4. Recordkeeping for calibration and maintenance.

Instrument Calibration

The instrument manufacturers detail procedures for calibrating LEL, carbon monoxide, hydrogen

sulfide, and/or oxygen meters will be followed. Calibration includes;

1. Clean air-zero point calibration;

2. Calibration of response with the appropriate span gas;

3. Checking and calibration, for actively pumped meters, of the air flow rate in the system;

4. Fault detection and subsequent maintenance; and

5. Record keeping.

Any decisions made to extend the period between calibrations or to lessen the rigor of calibrations

must first be formally evaluated by qualified persons against the manufacturer's recommendations,

industry best practices and governmental regulations. Requirements for specified, periodic

calibration of zero, span and flow are mandates, not recommendations. This applies for all systems,

but is especially critical for systems used in environments where air contaminants that may degrade

the meter's sensing element may be present.
DEECO Health and Safety Plan Page 40 January 2010

For gases and vapors other than those for which a device was calibrated, the manufacturer's

instructions and correction curves should be consult. Variations in response that may result in

incorrect readings from such interferences as:

1. Oxygen concentration;

2. Gas pressure;

3. Sensor poisons (i.e., silicon, silicates and organic lead, acid gases) and sensor depressants

(i.e., chlorinated hydrocarbons, acid gases); and

4. The fact that no reading will occur, or is even possible, for the detection of combustible

airborne mists or dusts, such as lubricating oils, coal dust or grain dust.

The portion of the calibration that deals with instrument airflow rate must include the blocked flow

alarm must being tested before and after each use. While this is a requirement for all such systems,

it is especially critical for instruments used in dusty environments.

Sampling Strategy

Measurement of values for each atmospheric parameter should be made for at least the minimum

response time of the instrument. When monitoring operations involving a descent into atmospheres

that may be stratified, the atmospheric envelope should be tested a distance of approximately four

feet in the direction of travel and to each side. If a sampling probe is used, the rate of progress

should be slowed to accommodate the sampling speed and detector response .

Any reading greater than zero should be followed by an assessment to:

1. Determine the source of the flammable vapors;

2. Eliminate the source, if possible; and

3. Ensure control of the source so that concentrations will not exceed (at most) 10% of the LEL

at any location where it is possible that an ignition source may be present.

Continuous or Follow-Up Monitoring

Continuous or follow-up monitoring may be required under conditions where the process, sequence

of work instructions or ambient conditions might reasonably be expected to change in a manner that

might increase the concentration of flammable gas or vapor. If conditions change during the course

of the permit period in a way that presents or could present additional hazards, then work will be

terminated until the area or conditions are made safe and permit conditions are re-evaluated.

Processes that may affect the composition, concentration, flow rate or volume, pressure and/or

temperature of flammable liquids, vapors or gases;

1. Processes adjacent to the process at which hot work is being performed;
DEECO Health and Safety Plan Page 41 January 2010

2. Ambient conditions such as temperature, wind direction and wind speed; and 

3. Other factors, such as the presence of uncontrolled vehicular traffic and/or ignition sources.

Documentation of Results (Record Keeping)

Each monitor obtained by DEECO will be assign a unique equipment identification (control) number

and complete records, including periodic performance, calibration and maintenance checks will be

maintained. 

2.29 Emergency Response/Evacuation Program

While at a client’s facility, follow their Emergency Response/Evacuation Program. The project

manager/field team leader will ensure that the employees are aware of the facilities’ Emergency

Response/Evacuation Program. Their plan should address the following;

1. Procedures for reporting a fire or other emergency;

2. Procedures for emergency evacuation, including type of evacuation and exit route

assignments;

3. Procedures to account for all employees after evacuation (head count);

4. Procedures to be followed by employees performing rescue or medical duties; and

5. The name or job title of every employee who may be contacted by employees who need more

information about the plan or an explanation of their duties under the plan.

Otherwise, when working at DEECO’s office, the following Emergency Response/Evacuation

procedures should be followed;

1. Report a fires or other emergencies by dialing 911. Administer first aid and/or CPR if you

trained. Do not attempt to fight any fires unless you have been trained in the use of fire

extinguishers;

2. Should an evacuation be necessary follow the escape route assignments. Exit diagrams are

place throughout the office to identify the escape routes to be followed by employees from

each specific facility location. Assist in the evacuation of any visitors and contractors; 

3. Account for employees after the evacuation to ensure that everyone got out. Designated

employees will sweep areas, checking offices and rest rooms, before being the last to leave

a workplace or conducting a roll call in the assembly area; and

4. Account for any visitors and contractors using the Visitors and Contractors Sign In Log.
DEECO Health and Safety Plan Page 42 January 2010

2.30 Compressed Air Systems

DEECO employees are not allowed to operate pneumatic power tools or use the compressed air

systems, air hoses, or air lines associated with pneumatic power tools.

2.31 Concrete Construction

DEECO employees are not allowed perform any concrete work, as described in OSHA 1926.700-

706.

2.32 Powder-Actuated Tools

DEECO employees are not allowed to use powder-actuated tools, as described in OSHA 1926.302

(e).
DEECO Health and Safety Plan Page 43 January 2010

3.0 Chemical Safety Guidelines

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

safety procedures, Field personnel are to follow the procedures which are more stringent. In all

cases, all OSHA and/or EPA requirements shall be met.

Field personnel are to refer to the Material Safety Data Sheet and chemical labels for specific

procedures and handling requirements. Copies of MSDSs for each chemical used, as well as for each

chemical Field personnel may be exposed to while on a client's site, must be made available. The

client is responsible for ensuring that MSDSs for chemicals used on the work site are available for

review. All Field personnel should refer to these MSDSs and be familiar with the properties and

handling requirements of all chemicals that may be used or encountered.

The required level of personal protective equipment for specific chemical hazards discussed in the

following sections depends on the situations at the work site. Decisions on the appropriate

equipment to be worn should be made by the project manager or coordinator.

The following information is DEECO's Chemical Hygiene Plan. Its intent is to protect laboratory

employees from health hazards associated with the use of hazardous chemicals in our laboratory and

to assure that our laboratory employees are not exposed to substances in excess of the permissible

exposure limits as defined by OSHA in 29 CFR 1910 subpart Z.

The plan is available to all employees fro review and a copy will be located in the Health and Safety

files. The plan will be reviewed annually by the Health and Safety Officer and/or the directors of

DEECO.

The following sections of this document and throughout the manual are standard operating

procedures for which each DEECO employee has received adequate training and direction. If

questions exist for the following information, it may be found throughout this manual or in our

memo file. It is the responsibility of each employee to be aware of DEECO's standard operating

procedures for the following:

Accidents, spills, avoidance of routine exposure, choice of chemicals, eating-drinking-smoking,

equipment and glassware, horseplay, mouth suction, personal apparel, housekeeping, personal

protection, planning, unattended operations, use of the hood, waste disposal and storage, working

alone, corrosives, fires, explosions, low temperature, pressurized and vacuum operations,

compressed gasses, chemical storage.

The following operations shall be performed in the LABORATORY FUME HOOD:

- Use of solvents unless in outdoor work areas

- Use of open flames or burning devices

- Use of any organic or inorganic chemical or compound that is unstable

These include preparation of standards, transfer of solvents, disposal or consolidation of waste 
DEECO Health and Safety Plan Page 44 January 2010

Respirators shall be used in accordance with DEECO's respiratory protection policy and with the

OSHA respirator standard 29 CFR 1910.134. This policy and associated documentation is filed in

the office of the Health and Safety Officer and/or safety files.

Appropriate protective apparel compatible with the required degree of protection for substances

handled shall be used. The Health and Safety Officer is available to advise employees on glove,

gown, eye protection, barrier creams, etc, use. Permeability Charts are available in any safety catalog

such as Lab Safety Supply, or SAFECO. Use of tradenames or references does not indicate a

recommendation or approval of listed products or Companies.

All eyewash stations are clearly marked and identified by the use of green placards and red arrows

leading to the eyewash areas. Employees who need to use the eyewashes are instructed as to their

use and must irrigate for a minimum of 15 minutes and seek medical assistance immediately.

Eyewashes will be inspected by the safety officer every month.

Employees have been issued a memorandum as to the procedures to follow for fires and explosions.

Exit routes are marked in each employee area. 

Fume hoods will be inspected every six months by the Health and Safety Officer. Adequacy of face

velocity will be determined by the use of a propeller anemometer and must reach a minimum of 200

fpm. An employee may request a hood inspection at any time should they suspect a problem with

the hood or ventilation system.

No employee will work with any hazardous chemicals unless they have been instructed by their

project manager or health and safety officer. These chemicals include; carcinogens, explosives,

neurotoxins, reproductive damaging chemicals, or acutely hazardous chemicals.

DEECO shall provide, to affected employees, medical attention including follow-up examinations

which MEDFIRST or another approved medical office determines is necessary under the following

circumstances.

a. whenever an employee develops signs and/or symptoms associated with a hazardous

chemical to which they may have been exposed, the employee shall be provided an

opportunity to receive appropriate medical examination. The employee shall contact the

Health and Safety Officer to initiate the medical program.

b. Where exposure monitoring reveals an exposure level routinely above the OSHA action level

(AL) (or in the absence of an action level, exposure above the OSHA permissible exposure

level (PEL)) for OSHA regulated substances for which there are medical monitoring

requirements, medical surveillance shall be established for that employee. Listed OSHA

standard medical surveillance requirements include the chemical benzene, formaldehyde,

methylene chloride.

c. Whenever an event takes place in the laboratory or work area such as a spill, leak, explosion,

or other occurrence resulting in the likelihood of a hazardous exposure, the affected

employee, laboratory or custodial, shall be provided an opportunity for a medical

consultation. This consultation is for the purpose of determining the need for a medical

examination.
DEECO Health and Safety Plan Page 45 January 2010

All aspects of these examinations are provided by a licensed physician, or supervised by a licensed

physician. These examinations are provided without cost to the employee, without loss of pay, and

at a reasonable time and place.

The Health and Safety Officer who is also the Chemical Hygiene Officer will provide information

to the physician:

1. Identity of the hazardous chemical to which the employee may have been exposed.

2. A description of the conditions of the exposure including exposure date if available

3. A description of the signs and symptoms of exposure that the employee is experiencing (if

any).

The physician's written opinion shall include:

1. Recommendations for future medical follow-up

2. Results of examination and associated tests

3. Any medical condition revealed that may place the employee at increased risk as the result

of a chemical exposure.

4. A statement that the employee has been informed by the physician of the results and told of

any medical conditions that may require additional examination of treatment.

3.1 General Characteristics

Routes of Entry

There are three major routes through which chemicals can enter the body and potentially cause harm.

Inhalation: Contaminants in the air can be absorbed into the bloodstream directly through the

lungs. In this manner, the contaminant can be carried to any organ in the body.

Ingestion: Ingestion of chemicals may severely damage the tissues of the digestive tract, damage

the stomach or other organs. The chemical can be absorbed into the bloodstream, or other body

fluids, and carried to other organs in the body.

Skin Absorption: The skin can act as a protective barrier to many chemical agents. However, many

chemicals can penetrate the skin. In this manner, the chemicals can enter the bloodstream and be

distributed throughout the body. Wounds on the skin (e.g. cuts and abrasions) offer a direct route

for chemicals to enter the bloodstream.

Physical Characteristics of Chemicals

Below are definitions of terms used in the following Chemical Safety Sections. Additional

definitions are located in the Guide to Common MSDS Terms, located in Appendix C.

Gas - a formless fluid which takes the shape of its container.

Vapor - the gaseous form of a substance which is normally a solid or liquid at room

temperature.

Fog - a visible, liquid aerosol.

Mist - a "fog" where the liquid particles are large enough to be individually seen.

Fume - particle formed by the condensation of vaporized solids.
DEECO Health and Safety Plan Page 46 January 2010

Dust - solid particles, capable of temporary suspension in air.

Smoke - airborne particles generated from incomplete combustion processes.

Carcinogen - a substance capable of causing cancer in animals or humans.

Mutagen - a substance capable of changing the genetic material in a living cell.

Fetotoxin - a substance capable of causing death or injury to fetus.

Teratogen - a substance which can cause deformations in a fetus from exposure of a

pregnant female.

Health Hazards

Substances to which field employees may be exposed have the potential to cause severe injury or

illnesses. The degree of injury or illness is a function of the exposure; that is the amount of the

substance and the time that an employee is in contact with it. Below are descriptions of various types

of health hazards that may exist when working with hazardous substances.

Irritant: Several chemicals may be an irritant to the skin, eyes, or respiratory tract. Irritation can

range from mild discomfort to severe and irreversible chemical burns on the skin or eyes. Examples

of irritants include ammonia, acids, bases, and several solvents.

Sensitizer: A chemical that is a sensitizer may not elicit a response after one exposure. After

repeated exposures, however, a severe reaction may occur, not necessarily at the point of contact.

The reaction may be a skin rash, or in the case of toluene diisocyanate, failure of the respiratory

system, Examples of sensitizers are formaldehyde, poison ivy, potassium dichromate.

Narcotic: Narcotics cause a depression of the central nervous system, producing a sleepy or dizzy

effect. Narcotics may make an employee unable to perform his/her work. Other safety hazards arise

when employees affected by a narcotic attempt to continue to work. Most organic solvents can

produce narcotic effects.

Asphyxiant: An asphyxiant reduces the amount of oxygen available for use by the body. This can

cause suffocation, leading to coma or even death. There are two types of asphyxiants. A Simple

Asphyxiant reduces the amount of oxygen in an area. Examples of simple asphyxiants include

carbon dioxide, nitrogen, argon, and other inert gases. A second type of asphyxiant is called a

Chemical Asphyxiant. A chemical asphyxiant enters the body through the lungs, and competes with

oxygen for space in the red blood cells. With these asphyxiants, suffocation can occur even if there

is plenty of oxygen in the room. Examples of chemical asphyxiants include carbon monoxide, and

cyanide gas.

Systemic Poison of Toxin: A systemic poison or toxin is a substance that produces an affect away

from the point of contact. For instance carbon tetrachloride can be inhaled or absorbed through the

skin, but exhibits its major effects upon the liver and kidneys.

It is important to remember that different chemicals react differently with the body. Several

chemicals exhibit more than one effect. The employee must review the MSDS for the specific

chemical he/she is working with to fully understand all of the potential hazards.
DEECO Health and Safety Plan Page 47 January 2010

3.2 Acids

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Acids are corrosive substances having a pH < 7.0.

2. Acid vapors and fumes can cause irritation of the eyes, skin, and respiratory tract.

3. Chemical burns on tissue can occur if acids are allowed to contact skin, eyes, or lungs.

4. Severe gastrointestinal pain and tissue injury can occur if acids are ingested.

Symptoms of Overexposure

Hazards of exposure are mainly from acute (short duration) exposures. Effects of acid fumes

or vapors include eye, throat, nose, or lung irritation. Skin or eye contact with acids may

result in severe chemical burns.

First Aid

In the event that acid comes in contact with your skin or eyes:

# Proceed immediately to the nearest eyewash station. Call for assistance from a coworker if necessary.

# Flush the affected area with copious amounts of water for at least 15 minutes. If

contact was with eye, pull the eyelid up and out, exposing the cornea, while flushing

with water.

# Notify the project manager or coordinator and seek medical attention.

If acid is spilled on your clothing:

# Remove contaminated clothing immediately.

# Flush skin area with water for 15 minutes.

# Notify the manager or coordinator and seek medical attention.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Protective Clothing (Saranex Tyvek Suits)

3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or

Organic Vapor/Acid Gas Cartridges.

4. Eyewear - Minimum of safety glasses with side shields. Recommend chemical splash

goggles.

3.3 Bases

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Bases are corrosive substances having a pH > 7.0.

2. Vapors and fumes generated from bases can cause irritation of the eyes, skin, and respiratory

tract.
DEECO Health and Safety Plan Page 48 January 2010

3. Chemical burns can occur if bases are allowed to contact skin or eyes. Bases can cause

irreversible damage to the eyes, even in dilute concentrations.

4. Severe gastrointestinal pain and tissue injury can occur if bases are ingested.

Symptoms of Overexposure

Hazards of exposure are mainly from acute (short duration ) exposures. Effects of alkali

fumes or vapors include eye, throat, nose, or long irritation. Skin or eye contact with bases

may result in severe chemical burns.

First Aid

In the event that a base comes in contact with your skin or eyes: 

# Proceed immediately to the nearest eyewash station. Call for assistance from a coworker if necessary.

# Flush the affected area with copious amounts of water for at least 15 minutes. If

contact was with eye, pull the eyelid up and out, exposing the cornea.

# Notify the project manager or coordinator and seek medical attention.

If a base is spilled on your clothing:

# Remove contaminated clothing immediately.

# Flush skin area with water for 15 minutes.

# Notify the project manager or coordinator and seek medical attention.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Protective Clothing (Saranex Tyvek Suits)

3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or

Organic Vapor/Acid Gas Cartridges.

4. Eyewear - Minimum of safety glasses with side shields. Recommend chemical splash

goggles.

3.4 Compressed Gases

Potential Hazards

Routes of Entry - Inhalation, Contact

1. Cylinders may explode if heated above 135 EF or dropped, damaging the valve stem.

2. Fire Hazards may exist if a Flammable Gas, Oxygen or other oxidizing gas cylinder is placed

near an open flame.

3 Skin and eye burns may result if direct contact with an escaping gas is made.

4. Suffocation can occur if the concentration of a gas is allowed to decrease the percent of

oxygen in an area.

5. If Oxygen is allowed to be released, it may be absorbed into clothing and take as long as 15

minutes to disperse. This could lead to a flash clothing fire if the person comes in contact

with an ignition source.

6. Severe burns may result from skin or eye contact with cryogenic gases.
DEECO Health and Safety Plan Page 49 January 2010

7. Prolonged breathing of oxygen can be toxic.

8. A fire or explosion hazard may exist when using nitrogen and helium, since these gases can

condense oxygen from the air, creating an oxygen-rich environment at the location of the gas.

Symptoms of Overexposure

Symptoms of overexposure to compressed gases depends on the specific gas. Refer to the

MSDS of the gas for this information.

General Handling Procedures

1. Cylinders should be tagged with a FULL, IN USE, or EMPTY Status Tag at all times.

2. Cylinders must have the valve protection cap in place when being moved.

3. Cylinders shall be stored such that they are protected from excessive heat or open flame (125

EF), physical shock, and electrical circuits.

4. Cylinders shall be secured using a chain or strap, to a wall, bench or other firm support.

5. Never completely empty a gas cylinder.

6. Never use oil on regulator valves or connections. Oil can degrade the regulator diaphragm,

contaminate the gas, or be oxidized in air to form explosive products.

7. Use only CGA (Compressed Gas Association) approved regulators and fittings for the

specific gas being used. Do not mix a given regulator with different gases.

8. Do not tamper with manufacturer's safety devices or check valves.

9. Leak-test all fittings and connections using an appropriate leak-test solution.

10. Jewelry should not be worn when handling or using cryogens.

11. If a cylinder should develop a leak:

# Remove all sources of spark or flame.

# Place in exhausted enclosure or remove to a safe outdoor area.

# Identify the cylinder as "Leaking Cylinder". Notify the supplier.

# For Flammable Gases, attach a control valve to the cylinder valve and allow the gas

to escape. Adjust to a moderate discharge rate.

12. If a cylinder containing cryogenic gases is dropped:

# Evacuate area within 100-ft radius of cylinder;

# Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel

relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is

venting gas, do not approach until there is no further discharge.

# When emission from the cylinder has not been noticed for 15 minutes, carefully open

the vent valve and the gas withdrawal valve to empty the cylinder. Move away from

the cylinder after opening valves.

# Once emptied, place in upright position. Write "Dropped Cylinder" on the cylinder

status tag and notify the supplier.

First Aid

If skin or eye contact occurs, flush area with unheated water and apply cold compresses.
DEECO Health and Safety Plan Page 50 January 2010

Personal Protective Equipment

Safety glasses should be worn at a minimum. Cryogenic gloves should be worn if contact with a

cryogenic gas is possible.

3.5 Cryogenic Materials

Cryogenic materials are substances that are kept at very low temperatures (less than 100 EF).

Cryogenics may be liquids or solids. Atmospheric gases, such as nitrogen, oxygen, or hydrogen, that

are cooled to temperatures less than 150 EF become liquified and are examples of cryogenic

materials. "Dry Ice" is another example of a super-cooled gas, carbon dioxide.

Potential Hazards

Routes of Entry - Contact, Inhalation

1. Severe burns may result from skin or eye contact with cryogenic materials.

2. Some liquid gases can deplete the available oxygen in a room Suffocation can result if not

used in a well-ventilated area.

3. Prolonged breathing of pure oxygen may have harmful physiological effects.

4. Nitrogen and helium can condense oxygen from the air, creating an oxygen-rich environment

at the location of the gas. This could be a fire or explosion hazard.

5. Cryogenic gases are stored under high pressure. This creates the same potential hazards as

other compressed gases (see Section 3.4).

6. Hydrogen is extremely flammable and is a fire and explosion hazard.

7. Liquid oxygen, while not flammable itself, does increase the flammability of ordinary

combustibles.

General Handling Procedures

1. When there is the potential for contact with a cryogenic material, a full face shield will be

required. In addition, a lab coat and gloves suitable for cold material handling shall be worn.

2. Jewelry should not be worn when handling or using cryogens.

3. When handling cryogens, trousers should not have cuff.

4. Use tongs to remove objects that are immersed in cryogenic liquids. Never use your hands,

even if wearing gloves!!

5. Use only in well-ventilated areas.

6. Store away from flammable and combustible materials.

7. Do not use near open flame or spark-producing equipment.

Emergency Procedures

1. If skin or eye contact occurs, flush area with unheated water and apply cold compresses.

Notify your supervisor and seek medical attention.

2. If a cylinder containing cryogenic gases is dropped:

# Evacuate area within 100-ft radius of cylinder;
DEECO Health and Safety Plan Page 51 January 2010

# Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel

relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is

venting gas, do not approach until there is no further discharge.

# When emission from the cylinder has not been noticed for 15 minutes, carefully open

the vent valve and the gust withdrawal valve to empty the cylinder. Move away from

the cylinder after opening valves.

# Once emptied, place in upright position. Write "Dropped Cylinder" on the cylinder

status tag and notify the supplier.

3.6 Flammable Liquids and Gases

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Flammable liquids and gases pose significant fire and explosion hazards.

2. Many flammable liquids:

# Can be readily absorbed through the skin.

# Can cause dermatitis.

# Are systemic poisons once in the body.

3. Eye, skin and respiratory tract irritation may occur.

4. Many flammable liquids and gases can produce depression of the central nervous system

(decreases motor response, dizziness, etc.)

Systems of Overexposure

Symptoms of overexposure to flammable liquids and gases will depend on the specific

substance. Refer to the MSDS of the chemical for this information.

General Procedures

1. Keep flammable materials away from open flame, sparks, or excessive heat.

2. Keep away from oxidizing agents such as oxygen.

3. Store in chemical cabinet, isolated from other chemicals.

4. Keep combustible material such as wood, cloth, and paper out of storage cabinets.

5. Do not leave containers of flammable materials in work areas overnight. Return all bottles

to the proper storage cabinet.

6. Flammable liquids and gases should be used only in well ventilated areas.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove

contaminated clothing. Seek medical attention.

2. In the event of a burn; extinguish flames by applying a fire blanket, or rolling on the floor.

Do not attempt to fan out the flames.

3. Use only an approved fire extinguisher to extinguish flames. Do not use water on flammable

liquid fires. Pouring water on these fires may only spread the flames over a wider area.
DEECO Health and Safety Plan Page 52 January 2010

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.

3.7 Organic Solvents

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Solvents can cause skin, eye and respiratory tract irritation.

2. Solvents may cause defatting of the skin, which lessens the ability of the skin to protect

against other chemicals.

3. Some solvents are also systemic toxins and can produce effects on the liver, kidneys, and

other organs if allowed to be absorbed through the skin.

4. Inhalation of solvent vapors may produce narcotic or anesthetic effects, and depression of

the central nervous system.

5. Many organic solvents are also flammable.

Symptoms of Overexposure

Symptoms of overexposure to solvents will depend on the specific substance. Refer to the

MSDS of the chemical for this information.

General Procedures

1. Use solvents only in local exhaust hood or well ventilated areas.

2. Do not continue to work if you feel dizzy or sleepy. Have a co-worker secure your apparatus

(turn off heat, close containers, etc.) and escort you away from the area.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected

clothing.

2. If dizziness occurs from inhalation, get to fresh air.

3. In the event of a spill:

# Turn off all sources of flame or sparks. Keep area well ventilated.

# Small spills can be handled by using a solvent spill kit.

4. Use only an approved fire extinguisher to extinguish flames. Do not use water on liquid

fires. Pouring water on these fires may only spread the flames over a wider area.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.
DEECO Health and Safety Plan Page 53 January 2010

3.8 Oxidizing Agents

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Oxidizing agents can be irritating to skin, eyes, and the respiratory tract.

2. Most oxidizing agents are highly reactive, and may react violently with metals, as well as

other chemicals.

3. Oxidizers are corrosive and can cause burns on skin and eyes.

4. Oxidizers spontaneously evolve oxygen, and therefore may create a fire on explosion hazard

in some environments.

Symptoms of Overexposure

Symptoms of overexposure to solvents will depend on the specific substance. Refer to the

MSDS of the chemical for this information.

General Procedures

1. Do not mix with organic solvents.

2. Always store in unbreakable, inert containers.

3. Do not use cork or rubber stoppers.

4. Respiratory protection is required when handling chlorine or bromine gas.

5. Label containers of oxidizers with the date received, and the date the container was first

opened.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected

clothing.

2. In the event of a spill:

# Turn off all spark and open flame sources.

# Cover spill area with a bisulfite solution. Mix well and spray with water. Place

waste in container with water.

3. If a gas leak occurs, remove all sources of spark or flame. Place cylinder in an exhausted

enclosure or remove it to a safe outdoor area as soon as possible.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.

3.9 Asbestos Awareness

Asbestos is the name applied to six naturally occurring minerals that are mined from the earth.

Because it is so hard to destroy asbestos fibers, the body cannot break them down or remove them

once they are lodged in lung or body tissues. They remain in place where they can cause disease. 

There are three primary diseases associated with asbestos exposure:

Asbestosis 

Lung Cancer 

Mesothelioma 
DEECO Health and Safety Plan Page 54 January 2010

DEECO personnel may be exposed to asbestos while on a client's premises. The most common use

of asbestos at our client’s facilities is insulation on pipes and vessels. Asbestos boiler insulation

does not present a hazard unless the protective covering is cut or damaged in such a way that the

asbestos underneath is actually exposed to the air. The project manager/field team leader will ensure

that the client has identified or provided means to identify asbestos-containing equipment. 

If you do not know whether something is asbestos or not, assume that it is until it is verified

otherwise.

DO NOT DISTURB IT. 

Never...

Drill 

Hammer 

Cut 

Saw 

Break 

Damage 

Move 

Disturb 

...any asbestos-containing materials or suspected materials.

3.10 Benzene Awareness

Benzene is a volatile chemical formed from both natural processes and human activities. Natural

sources of benzene include emissions from volcanoes and forest fires. Benzene is also a natural part

of crude oil, gasoline, and cigarette smoke. Benzene is widely used in the United States, ranking in

the top 20 chemicals for production volume. It is primarily used as a solvent, as a starting material

for the production of other chemicals, and as a gasoline additive. Breathing benzene can cause

drowsiness, dizziness, and unconsciousness; long-term benzene exposure causes effects on the bone

marrow and can cause anemia and leukemia. The Occupational Safety and Health Administration

(OSHA) recognizes benzene as a hazardous material and imposes strict exposure limits in the

workplace. 

It is unlikely that DEECO personnel would be exposed to benzene on a client's premises at levels

above the OSHA permissible exposure limits (1 ppm TWA for 8 hour and 5 ppm STEL for 15

minutes). If the potential for benzene exposure exists, the project manager/field team leader will

ensure that the client has identified regulated areas where the permissible exposure limits could be

exceeded.

DEECO does not use benzene for any sample recovery procedures.

3.11 Hydrogen Sulfide Awareness

Hydrogen sulfide (H2S) is a colorless gas with a powerful nauseating smell of rotten eggs. The odor

is a poor warning property because hydrogen sulfide exposure quickly deadens the sense of smell.

The gas is heavier than air and may collect in low areas such as sewers, pits, tunnels or gullies. High

airborne levels of hydrogen sulfide (between 4.3 and 46.0 percent of gas by volume in the air) may

catch fire if there is a source of ignition. If the gas is burned, toxic products such as sulfur dioxide
DEECO Health and Safety Plan Page 55 January 2010

will be formed. Hydrogen sulfide is incompatible with oxidizing agents, such as nitric acid and

chlorine trifluoride, and may react violently or ignite spontaneously.

Hydrogen sulfide is extremely toxic. It may cause death instantaneously in high airborne

concentrations. Low levels may be extremely irritating to the lungs, nose, throat and eyes. 

Hydrogen sulfide can be detected by smell at levels as low as 0.13 parts hydrogen sulfide per million

parts air (ppm). Odor cannot be used as a warning because the gas can deaden the sense of smell

within 2 to 15 minutes in exposures of approximately 100 ppm. A single breath of hydrogen sulfide

at about 1000 ppm may paralyze the respiratory system and result in coma and death. Convulsions

may also occur. Prolonged exposure at about 250 ppm hydrogen sulfide may cause the lung tissue

to swell and fill up with water (pulmonary edema). 

This effect may occur after the exposed worker recovers from the irritant effects of the gas.

Exposures of 20 to 50 ppm hydrogen sulfide for one hour may cause inflammation of the cornea and

the delicate lining of the eye and eyelid (a condition called keratoconjunctivitis). Exposures for long

periods at 50 ppm may cause severe irritation of the nose, throat and lungs. Workers exposed to

lower concentrations of hydrogen sulfide may develop headaches, eye disorders and chronic

bronchitis. 

DEECO personal may be exposed to hydrogen en sulfide on a client's premises at levels above the

OSHA permissible exposure limits (20 ppm (ceiling) with the following exception: if no other

measurable exposure occurs during the 8-hour work shift, exposures may exceed 20 ppm, but not

more than 50 ppm (peak), for a single time period up to 10 minutes.). Small amounts of hydrogen

sulfide occur in crude petroleum but natural gas can contain up to 90%. By far the largest industrial

route to H2S occurs in petroleum refineries. Other sources of hydrogen sulfide include coke ovens,

paper mills (using the sulfate method), and tanneries. H2S arises from virtually anywhere where

elemental sulfur comes into contact with organic material, especially at high temperatures.

Should the potential exist for exposure to H2S, the project manager/field team leader will work with

the client to ensure that all personnel are provided with the following training;

1. Identification of the characteristics, sources, and hazards of Hydrogen Sulfide, 

2. Proper use of the Hydrogen Sulfide detection methods used on the site,

3. Recognition of, and proper response to, Hydrogen Sulfide warnings at the workplace,

4. Symptoms of Hydrogen Sulfide exposure,

5. Proper rescue techniques and first-aid procedures to be used in a Hydrogen Sulfide exposure,

6. Proper use and maintenance of personal protective equipment. Demonstrated proficiency in

using PPE should be required,

7. Worker awareness and understanding of workplace practices and maintenance procedures

to protect personnel from exposure to hydrogen sulfide,

8. Wind direction awareness and routes of egress,

9. Confined space and enclosed facility entry procedures.

10. Locations and use of safety equipment,

11. Locations of safe briefing areas,

12. Use and operation of all Hydrogen Sulfide monitoring systems, and

13. Emergency response procedures, corrective action, and shutdown procedures.
DEECO Health and Safety Plan Page 56 January 2010

At most client facilities where hydrogen sulfide exposure could occur, this training is required by

the client prior to entry.

3.12 Lead Awareness

Lead is a toxic metal that was used for many years in products found in and around our homes. Lead

also can be emitted into the air from motor vehicles and industrial sources, and lead can enter

drinking water from plumbing materials. Lead may cause a range of health effects, from behavioral

problems and learning disabilities, to seizures and death. Children six years old and under are most

at risk.

Most Common Sources of Lead Poisoning:

1. Deteriorating lead-based paint,

2. Lead contaminated dust, and

3. Lead contaminated residential soil 

DEECO personal may be exposed to lead hazards created by renovation, repair and painting (RRP)

activities at client facilities that disturb lead-based paint. The lead exposure limit is fifty micrograms

per cubic meter of air (50 ug/m3

) averaged over an 8-hour period. The project manager/field team

leader will ensure that the client has identified any areas where the potential for exposure to lead

exists and access these areas by DEECO employees will be prohibited.
DEECO Health and Safety Plan Page 57 January 2010

4.0 Hazard Communication Requirements

Introduction

The Occupational Safety and Health Administration's (OSHA) Hazard Communication Regulation

(29 CFR 1910.1200) requires that employees be informed of all hazardous chemicals located in their

workplace.

This program will describe how DEECO intends to protect the safety and health of our employees

who are exposed to hazardous chemicals in the workplace, and to comply with the provisions of 29

CFR 1910.1200.

Each supervisor will be held responsible for strict adherence to these policies and will closely

monitor all activities involving hazardous chemicals.

Each employee will carefully follow established work practices and promptly report observed or

potential problems to supervision.

There is no job at DEECO so vital or urgent as to justify the risk of employee overexposure to a

hazardous chemical. Ask when in doubt. Proceed with a job only after being satisfied that it is safe

for you to do so.

A list of all hazardous chemicals for each workplace has been made and is readily available, upon

request, to any employee, working on any shift. It is located in each tow vehicle, shop area, and wet

chemistry lab.

DEECO is responsible to ensure that the list of hazardous chemicals is kept current and that a current

MSDS for each hazardous chemical used is on hand. A chemical that is not shown on the current

list will not be ordered without prior coordination with the wet chemistry lab manager.

All containers of hazardous chemicals in each workplace will be conspicuously labeled with the

identity of the chemical, and the appropriate hazard warnings. If the chemical is a known or

suspected carcinogen, or it is known to affect a specific organ of the body, this information will also

be placed on the container label. The person having supervisory responsibility for the storage or use

or each hazardous chemical will ensure that such labels are not defaced and that they remain legible

at all times. The health and safety officer will ensure that an adequate supply of labels are on hand

and made available to the responsible supervisors.

When an outside contractor is used, it will be the responsibility of the project manager to advise the

contractor of any hazardous chemical to which their employees may be exposed and the appropriate

protective measures to be taken. This procedure also works conversely.

All employees exposed to any hazardous chemicals will complete an information and training

program which includes at least the subjects listed below. New employees must complete similar

instructions before initial exposure to any hazardous chemical in the workplace.
DEECO Health and Safety Plan Page 58 January 2010

Adequate training of all employees exposed to hazardous chemicals will be given by the Health and

Safety Officer or an approved training instructor and assisted as needed by the Hazard

Communication Program Monitor.

Employee information for this program will include:

1. The purpose and need for such a program, including the basic concept that gives every employee

the right to know about hazardous chemicals with which they work.

2. The location and availability of the written Hazard Communication Program, plus the list of

hazardous chemicals and their corresponding MSDS's.

3. The identity upon request, of any chemical to which the employee id exposed. In the case of a

trade secret chemical, the name on the MSDS will be provided.

Employee training shall include at least the following:

1. Methods and observations used to detect the presence or release of a hazardous chemical in the

work ares such as monitoring devices, appearance, or odor.

2. The physical and health hazards associated with each chemical, as specified in the MSDS.

3. Action that employees can take to protect their own safety and health, including specific

procedures that have been established for normal work practices, emergency procedures, and policies

on the use of personal protective equipment.

4. Details of the Hazard Communication Program, including an explanation of the labeling system

used on in-house containers of hazardous chemicals. Also, details of how employees can obtain and

use information contained in the MSDS.

It is the intent of DEECO management to protect the safety and health of each employee, our most

valuable and valued asset. By following correct procedures, no employee should experience and

harmful effects from working with chemicals in their workplace.

Client Responsibilities

Clients are required to inform DEECO personnel working on the premises of all hazards located in

the area. In addition to chemical hazards, the client should inform DEECO:

# Location of all emergency exits.

# Location of nearest medical facilities.

# Location of nearest emergency equipment (fire extinguishers, safety showers,

eyewashes, etc.)

The client should have available for DEECO personnel MSDSs on all chemicals located in the

area(s) where DEECO will be performing work.

The team leader should ensure that the above information is obtained before setting up equipment

to perform the work.
DEECO Health and Safety Plan Page 59 January 2010

DEECO Responsibilities

DEECO is required to inform its employees of all hazards that they may contact. MSDSs for each

chemical used by the Field Division are available in the central MSDS file located at the field office.

DEECO must also supply the client, upon request, information on the chemicals which DEECO

brings on the client's premises to perform field work. MSDSs are present prior to entering the

client's premises.

Written Program

The OSHA regulation requires that DEECO have a written Hazard Communication Program. The

written program for the Field Division is located in Appendix D of this Health and Safety Plan.

4.1 Material Safety Data Sheets

The manufactured or distributor of chemicals used by DEECO is required to supply DEECO with

a MSDS. Employees must be informed of the information on the MSDS prior to working with a

chemical.

A MSDS must exist for all hazardous chemicals. MSDSs for chemicals used on a client's site must

be available for review or photocopying by the client. A list of all chemicals brought on site by

DEECO should be supplied to the client. The client should be informed that a MSDS is available

for each chemical on that list.

Hazardous materials that require a MSDS are substances which may present a physical or health

hazard. A material presents a Physical Hazard if it is:

# Flammable

# Combustible

# Explosive

# Reactive

# Under Pressure

A material presents a Health Hazard if it is:

# Corrosive

# An Irritant

# A Sensitizer

# A Carcinogen

# Harmful to body organs, including skin, eyes, reproductive organs, liver, kidneys,

lungs, blood, or nervous system.

Each MSDS is required to provide the user with the following information:

Section I - Supplier Information. This section must include the manufacturer's name, address, and

an emergency telephone number. Also included in Section I is the name of the chemical as it appears

on the chemical label. Synonyms for the chemical name may also be given.
DEECO Health and Safety Plan Page 60 January 2010

Section II - Hazardous Ingredients Information. This section will list all the hazardous ingredients

of the chemical if they constitute 1% of the mixture or more. If the hazardous ingredient is a

carcinogen (capable of causing cancer), the ingredient will be listed if it constitutes 0.1% of the

mixture or more. Also listed for each ingredient will be the percentage that it makes up of the

mixture, and its current permissible exposure level (PEL).

Section III - Physical/Chemical Characteristics. This section will list characteristics such as boiling

point, vapor pressure, specific gravity, melting point, vapor density, evaporation rate, and solubility

in water. The substance's appearance and odor characteristics will also be given.

Section IV - Fire and Explosion Hazard Data. Included in this section will be the chemical's flash

point, flammability limits (upper and lower), the correct type of material to use to extinguish a fire,

any unusual fire and explosion hazards, and any special fire fighting procedures.

Section V - Reactivity Data. This section will list any conditions that should be avoided with this

chemical, whether or not the chemical is stable, substances the chemical is incompatible with, any

hazardous decomposition products or any hazardous polymerization that may occur.

Section VI - Health Hazard Data. Information included in this section will be possible routes of

exposure, signs and symptoms of overexposure (both acute and chromic exposures), medical

conditions that may be aggravated by exposure to this chemical, and emergency first aid.

Section VII - Precautions for Safe Handling. This section will list steps to be taken in the event of

a spill or release of the chemical, the proper waste disposal methods, and any precautions that should

be taken during handling and storage.

Section VIII - Control Measures. Included in this section will be the proper personal protective

equipment (respiratory protection, gloves, eye/face protection), the required ventilation system, and

other work practices that should be followed when using this chemical.

Section IX - Additional Information. This section will list any other pertinent information such as

transportation requirements or where to get other information regarding the chemical.

4.2 Chemical Labelling

All chemicals used in the field or at DEECO must be labelled. Chemical containers received from

the manufacturer are required to contain the chemical's name, hazard warnings, and the

manufacture's name and address. This manufacturer's label may not be defaced in any manner.

Beakers and other containers used by DEECO employees must also be clearly labelled with the

chemical name at all times.

Several chemical manufacturers place the NFPA (National Fire Protection Association) hazard label

on the bottle. This label identifies some of the hazardous properties of the chemical. 

Transfer containers used by more than one employee must be labelled. Chemical formulas must not

be used (for example, use "Acetone" instead of CH3COCH3

).
DEECO Health and Safety Plan Page 61 January 2010

4.3 Employee Exposure Monitoring

In order to ensure that field personnel are not overexposed to hazardous materials, the DEECO

Safety Officer may direct the Project Manager or Coordinator to perform employee exposure

monitoring.

Results from monitoring surveys will be forwarded to the department managers. The manager must

review the report with each employee in the department. This can be accomplished by reviewing

the report in a department meeting or circulating the report to all employees. Employees must sign

an Employee Notification Form which accompanies the report. The employees' signatures indicate

that the report was reviewed and understood by each employee. The decision to monitor employee

exposure will be made on a project-by-project basis by the DEECO S.O. and the Project Manager

or Coordinator.

The department managers must retain copies of all monitoring reports. These reports should be

reviewed with all new employees, or employees being reassigned to the area, before allowing the

employee to work in the area.

Employees may review past sampling reports that are representative of their exposure by contacting

their department manager, the Director of Personnel, or the DEECO S.O.

4.4 Employee Medical Surveillance

DEECO requires each employee to take a pre-employment physical. This physical establishes the

employee's physical condition before performing work at DEECO. In addition, DEECO field

employees will receive annual physicals based upon their job description and age.

Employees may receive additional medical evaluation if:

# Signs or symptoms associated with exposure to a hazardous chemical at DEECO

develop.

# Routine exposure monitoring indicate that employee exposure exceeds the

Permissible Exposure Level or Action Level for a given substance.

# A spill, leak or other event occurs which may have resulted in exposure to a

hazardous exposure.

These physicals will be provided during normal working hours (when possible) and at no cost to

employees. Copies of all medical evaluations will be forwarded to the Director of Personnel for

placement in the employee's confidential, personal file. Physical evaluations made under the above

conditions shall not reveal findings of diagnoses unrelated to the employee's occupational exposure.

Employees may at any time, review all medical information on file by contacting either the

department manager or the Director of Personnel.

4.5 Employee Access to Records

Employees may be asked to participate in chemical exposure monitoring. DEECO will maintain

records of employee medical surveillance, exposure monitoring, and occupational accidents or

injuries. As per OSHA regulations, this information may be reviewed by employees by requesting
DEECO Health and Safety Plan Page 62 January 2010

the information from the Area Supervisor, Manager or the Personnel Director. A copy of the OSHA

standard regarding access to exposure and medical records may be obtained from the DEECO S.O.

Responsibilities

The DEECO Safety Officer must ensure that:

# All employee exposure monitoring reports are reviewed by employees, and that

employees acknowledge the receipt of the reports by signing the report.

# Copies of the signed report are sent to the Personnel Director.

# Other information, such as MSDSs, ventilation records, etc. are maintained for at

least 30 years.

The Personnel Director must ensure that:

# Employee medical, exposure and accident/injury records are maintained for the

length of employment plus thirty (30) years.

# A response to any internal and external requests for medical or exposure records is

given within 15 working days.

The Department Managers must ensure that:

# Employees review and sign all Employee Exposure reports.

# Employees are advised of the right to access medical and exposure records annually

in a department safety meeting.
DEECO Health and Safety Plan Page 63 January 2010

5.0 Personal Protective Equipment

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

requirements for personal protective equipment, field personnel are to follow the procedures which

are more stringent. In all cases, all OSHA and/or EPA requirements are to be met. Field personnel

are not to use personal protective equipment for which they have not received adequate training in

their use and limitations.

Protective equipment, including personal protective equipment for eyes, face, head, and extremities,

protective clothing, respiratory devices, and protective shields and barriers, will be provided, used,

and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of

processes or environment, chemical hazards, radiological hazards, or mechanical irritants

encountered in a manner capable of causing injury or impairment in the function of any part of the

body through absorption, inhalation or physical contact.

Where employees provide their own protective equipment, DEECO will be responsible to assure its

adequacy, including proper maintenance, and sanitation of such equipment.

All personal protective equipment shall be of safe design and construction for the work to be

performed. The protective equipment, including personal protective equipment (PPE) will be

provided by DEECO at no cost to employees. DEECO will pay for replacement PPE, except when

the employee has lost or intentionally damaged the PPE.

5.1 Respiratory Protection

Detailed information regarding the use of specific respirators is located in the DEECO Field Division

Written Protection Program.

Use

Only employees that have been trained in the use of respiratory protection shall select or wear

respirators. Employees must:

# Be fit-tested and trained annually.

# Ensure that equipment is clean, available, and in good repair.

# Use equipment only as instructed.

# Receive medical clearance to wear a respirator.

# Not have beards, long side-burns, or other conditions that may preclude a good faceto-facepiece seal.

# Ensure that the proper respirator cartridge or canister is used for a particular

contaminant. All cartridges are marked and color-coded.

When donning the respirator:

# Place mask on face with chin in chin-cup.

# Attach lower straps around neck.

# Place top straps on crown of head, above ears.

# Tighten all straps.
DEECO Health and Safety Plan Page 64 January 2010

Each time the respirator is conned, positive and negative pressure fit-checks must be performed.

Positive Pressure Fit-Checks:

# Place the palm of hand over the exhalation valve.

# Exhale gently. The mask should lift off the face without allowing the air to escape.

Negative Pressure Fit-Checks:

# Cover the inlets of the cartridges with hands.

# Inhale gently. The mask should collapse around the face without letting air in around

the face-to- respirator seal.

Selection

Respirators provide specific Protection Factors based on the type to respirator and the cartridge or

canister in use. The Protection Factor is defined as the concentration of an air contaminant outside

the mask divided by the concentration of that some contaminant inside the mask. For example, the

half-mask respirator with HEPA (High Efficiency Particulate Absolute) filter cartridge has a

Protection Factor of 10. This indicates that if worn in an area with a concentration of 0.05 mg/m3

of airborne lead, the employee would actually be exposed to 0.005 mg/m3 of lead.

Employees should select the type of respirator and cartridge based on the decision criteria located

in the DEECO Respiratory Protection written program.

Inspection

Employees must inspect each respirator prior to donning. Straps, inhalation and exhalation valves,

cartridge gaskets, and facepiece should be inspected to ensure all parts are present, clean and in good

condition.

Decontamination

Respirator should be cleaned after each use. Remove cartridges and place them in a plastic bag.

Wash respirator with warm, soapy water. Rinse the respirator thoroughly since soap can be a skin

irritant. Allow respirator to air dry. Place in plastic bag when dry and store in dry location away

from excessive heat. Do not place anything on top of respirator since this may distort the facepiece.

Breathing Air Quality and Use

When DEECO employees are required to use atmosphere-supplying respirators (supplied-air and

SCBA), DEECO will ensure that compressed air, compressed oxygen, liquid air, and liquid oxygen

used for respiration accords with the following specifications:

1. Compressed and liquid oxygen shall meet the United States Pharmacopoeia requirements for

medical or breathing oxygen;

2. Compressed breathing air shall meet at least the requirements for Grade D breathing air

described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-

1989, to include and oxygen content (v/v) of 19.5-23.5%, a hydrocarbon (condensed) content

of 5 milligrams per cubic meter of air or less, a carbon monoxide (CO) content of 10 ppm

or less; a carbon dioxide content of 1,000 ppm or less; and lack of noticeable odor.
DEECO Health and Safety Plan Page 65 January 2010

DEECO will ensure that compressed oxygen is not used in atmosphere-supplying respirators that

have previously used compressed air and ensure that oxygen concentrations greater than 23.5% are

used only in equipment designed for oxygen service or distribution.

DEECO will ensure that cylinders used to supply breathing air to respirators meet the following

requirements:

1. Cylinders are tested and maintained as prescribed in the Shipping Container Specification

Regulations of the Department of Transportation (49 CFR part 173 and part 178);

2. Cylinders of purchased breathing air have a certificate of analysis from the supplier that the

breathing air meets the requirements for Grade D breathing air; and

3. The moisture content in the cylinder does not exceed a dew point of -50 deg.F (-45.6 deg.C)

at 1 atmosphere pressure.

DEECO will ensure that compressors used to supply breathing air to respirators are constructed and

situated so as to:

1. Prevent entry of contaminated air into the air-supply system;

2. Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F

(5.56 deg.C) below the ambient temperature;

3. Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air

quality. Sorbent beds and filters shall be maintained and replaced or refurbished periodically

following the manufacturer's instructions;

4. Have a tag containing the most recent change date and the signature of the person authorized

by the employer to perform the change. The tag shall be maintained at the compressor.

For compressors that are not oil-lubricated, the DEECO will ensure that carbon monoxide levels in

the breathing air do not exceed 10 ppm.

For oil-lubricated compressors, the DEECO will use a high-temperature or carbon monoxide alarm,

or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply

shall be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from

exceeding 10 ppm.

The DEECO will ensure that breathing air couplings are incompatible with outlets for non-respirable

work site air or other gas systems. No asphyxiating substance shall be introduced into breathing air

lines.

DEECO will use breathing gas containers marked in accordance with the NIOSH respirator

certification standard, 42 CFR part 84.
DEECO Health and Safety Plan Page 66 January 2010

5.2 Gloves

Use & Selection

Gloves should be worn when there is a potential for skin contact, such as pouring chemicals,

washing glassware with solvents, collecting samples, etc. Different gloves protect against different

chemicals. The glove compatibility chart below should be consulted when selecting gloves.

Inspection

Employees must check the gloves before donning by:

# Inspecting for cracks, holes, or tears.

# Performing a leak test by grasping the cuff of the glove quickly such that air is

trapped inside the glove. Squeeze the glove to ensure that air cannot escape. If a

glove has any hole, crack, or tear, or has evidence of degradation to the material,

discard the glove.

Employees must ensure that an ample supply of the proper gloves are always available in the field.

Decontamination

Employees should rinse gloves with water before removing. Gloves should be turned inside-out

during removal. Contaminated gloves are to be discarded.

Glove Selection Chart

Chemical(s) Glove Type

Solvents Nitrile (Sol-Vex)

-Chlorinated PVA

Acids, Bases Nitrile (Sol-Vex)

Neoprene (Stanzoil)

PVC Coated

Sample Collection Disposible Latex

5.3 Protective Eyewear

Use & Selection

Chemical and physical hazards in the field have the potential to produce injuries to the eye and face.

These injuries could seriously impair or destroy vision, or permanently destroy facial skin. DEECO

provides eye and face protective equipment to employees at no cost. 

It is the responsibility of the Field Coordinator and Field Employees to ensure that proper eye and

face protection is available and worn in the work area. Contact lenses may not be worn in areas

requiring safety glasses.
DEECO Health and Safety Plan Page 67 January 2010

Eyewear Hazards

Safety Glasses To be worn at all times on the work site or in designated "Eye

Protection Required" areas.

Safety Goggles To be worn whenever there is a potential of a chemical splash

(e.g. handling or pouring solvents.)

Face Shields To be worn when handling or pouring acids, bases, or other

corrosive chemicals; when there is a potential of flying debris

from drilling, cutting or grinding materials with power tools.

Inspection

All safety glasses must meet the American National Standards Institute (ANSI) Standard Z87.1.

Safety glasses are required to have "Z87.1" stamped on the inside of the frame, or etched on the

lenses. DEECO will provide prescription safety glasses to those employees that require corrective

lenses.

Safety glasses, goggles, or face shields that show visible signs of deterioration or damage should be

repaired or discarded. If a damaged item is to be repaired, it should be placed in a plastic bag,

sealed, and labeled "DAMAGED EQUIPMENT: FOR REPAIR".

Decontamination

All safety eyewear should be thoroughly cleaned with soap and water after each use in a

contaminated, or potentially contaminated, area.

5.4 Protective Clothing

In many work situations it may be necessary for field personnel to wear full body protective clothing.

The Project Manager or Coordinator should identify the types of protective clothing that may be

necessary for a particular project, and ensure that the equipment is available at the work site. Brief

descriptions of the various protective clothing materials are given below. In most situations, only

Tyvek or Saranex clothing will be necessary.

Standard Tyvek (non-porous)

Non-woven, olefin fiber fabric. Suitable for protection against most dusts, mists, and fumes.

Fabric melts at temperatures above 270 EF. Should not be used to protect against solvent

vapors or acid gases/fumes.

Saranex Tyvek

Standard Tyvek which has one side coated with saranex plastic. This gives the clothing a

high level of resistance to most hazardous chemicals, including PCBs. Should not be used

in temperatures above 270 EF.
DEECO Health and Safety Plan Page 68 January 2010

Polyethylene Coated Tyvek

Standard Tyvek which has one side coated with polyethylene. This gives the clothing a high

level of resistance to most hazardous chemicals, including PCBs. More resistent to moisture,

and will protect individuals against chemical spills and splashes better than the Saranex

Tyvek. Should not be used in temperatures above 270 EF.

Protective clothing is available in other materials, such as polyvinyl chloride, neoprene, Viton, and

butyl rubber. These materials protect against a higher degree of hazard than Field personnel would

be expected to encounter. If the Project Manager or Coordinator feels that additional protection is

required for a specific project, he/she should discuss clothing options with the S.O.

5.5 OSHA Levels of Protection

Use & Selection

Employees should select the level of personal protective equipment required for each individual

work site based on the current EPA guidelines below. Employees are not to perform tasks in the

work area if the proper personal protective equipment is not available or in good working condition.

At a minimum, employees must wear safety glasses and safety shoes/boots at all work sites. DEECO

employees will not enter areas requiring Level A or Level B protection. All employees will be

trained on the proper use of protection equipment for Level C and Level D protection.

Levels of Protection

Level A - Highest level of respiratory, skin and eye protection is needed. Criteria include:

# High concentration of vapors, gases or particulates.

# High potential for splash, immersion or potential exposure to highly toxic

materials.

# Confined or poorly-ventilated areas.

Equipment:

# Supplied air respirator (pressure-demand SCBA or airline respirator with

escape bottle)

# Fully encapsulating chemical resistent suit

# Inner gloves, chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes coveralls, long cotton underwear, hard hat, disposable gloves and boot

covers, cooling unit, 2-way radios.

Level B - Highest level of respiratory protection, lesser level of skin protection. Criteria include:

# Atmospheres immediately dangerous to life and health (IDLH)

# Oxygen deficient atmosphere (<20%).

# Low potential for splash, immersion or potential exposure to highly toxic

materials.
DEECO Health and Safety Plan Page 69 January 2010

Equipment:

# Supplied air respirator (pressure-demand SCBA or airline respirator with

escape bottle)

# Chemical resistent clothing

# Outer gloves, chemical resistent

# Inner gloves, chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes long cotton underwear, hard hat, disposable gloves and boot covers,

cooling unit, 2-way radios.

Level C - Conditions allow the use of air-purifying respirators. Criteria include:

# Oxygen concentrations not less than 20%.

# Concentrations of identified contaminants will be reduced by the respirator

below the contaminants TLV, and the concentration is within the service limit

of the canister/cartridge.

# Concentrations of contaminants to not exceed IDLH levels.

# Low potential for splash, immersion or potential exposure to highly toxic

materials.

# FID or PID measurements show concentrations only a few ppms above

background.

Equipment:

# Air-purifying, full-face respirator with appropriate canister or cartridges 

# Chemical resistent clothing

# Outer gloves. Chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes long cotton underwear, hard hat, disposable gloves and boot covers,

escape mask, hard hat, 2-way radios.

Level D - No respiratory or skin hazards exist. Criteria include:

# No contaminants present.

# No potential for splash, immersion or potential exposure to any chemicals.

Equipment:

# Coveralls or work clothing

# Safety shoes/boots

# Safety glasses

# Hard hat

Optional Equipment includes gloves, face shield.
DEECO Health and Safety Plan Page 70 January 2010

5.5 Training for the Use Personal Protective Equipment

DEECO will provide training to each employee who is required to use PPE. Each such employee

will be trained to know when PPE is necessary, what PPE is necessary, how to properly don, doff,

adjust, and wear PPE, the limitations of the PPE, and the proper care, maintenance, useful life and

disposal of the PPE.

Each affected employee will be required to demonstrate an understanding of the training and the

ability to use PPE properly, before being allowed to perform work requiring the use of PPE.

When DEECO has reason to believe that any affected employee who has already been trained does

not have the understanding and skill required, DEECO will retrain each such employee.

Circumstances where retraining is required include, but are not limited to, situations where changes

in the workplace render previous training obsolete, changes in the types of PPE to be used render

previous training obsolete, or inadequacies in an affected employee's knowledge or use of assigned

PPE indicate that the employee has not retained the requisite understanding or skill.

DEECO will verify that each affected employee has received and understood the required training

through a written certification that contains the name of each employee trained, the date(s) of

training, and that identifies the subject of the certification.









































































































































































































































































































































































































































on value in

me (ppmvd

en. If the te

ction limit

ion limit in

Exhaust Flowrate (select flowrate units)Worksheet Title: HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet? Facilities that use Method 321 to test for HClCompany Name:

Facility Name:Address:City:

State:Kiln ID:Kiln Type: Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill: Yes or NoControl Device Configuration: Enter all installed air pollution control devices here

Parameter

Sample #1

Sample #2

Sample #3

Test AverageUnits

Units Other 

DescriptionTest Method Used Test Locatio

Enter HCl concentratiparts per million volucorrected to 7% oxygresults are below deteplease note the detectbrackets (e.g., [< 0.010]). 

Select approprfrom list. If othselected pleaseunits in column

 dry 

) 

st 

, iate unit 

er is 

 describe 

 H at right. Enter the name of the Test Method used.

Indicate whether the occurred upstream odownstream of a condevice(s); list the codevice(s)

Sample Date (mm/dd/yyyy)HCl Concentration ppmvd @ 7% O2Exhaust Stream %Moisture %

Exhaust Flowrate (select flowrate units)Exhaust Temperature (select temperature units)Sample Date (mm/dd/yyyy)HCl Concentration ppmvd @ 7% O2

Exhaust Stream %Moisture %Exhaust Flowrate (select flowrate units)

Exhaust Temperature (select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a response
value in dr

vd) correc

ults are be

te the dete

Exhaust Flowrate 161400 164100 166000 dscfmWorksheet Title: HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet? Facilities that use Method 321 to test for HClCompany Name: Holcim (US), Inc.Facility Name: AdaAddress: 1100 West 18th StreetCity: AdaState: OKKiln ID: Long WetKiln Type: Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill: Yes or No NOControl Device Configuration: ESP

Parameter

Sample #1

Sample #2 e Sampl #3

Test AverageUnits

Units Other 

DescriptionTest Method Used Test Lo

Enter HCl concentration per million volume (ppm7% oxygen. If the test resdetection limit, please nolimit in brackets (e.g., [< 0.010]). 

Select apprfrom list. Ifselected pleunits in col

y parts 

ted to 

low 

ction 

opriate unit 

 other is 

ase describe 

umn H at right. Enter the name of the Test Method used.

Indicate whethoccurred upstrdownstream of device(s); list tdevice(s)

Sample Date (mm/dd/yyyy) 3/12/2010 3/12/2010 3/12/2010HCl Concentration 1.66 1.34 1.25 1.42 ppmvd @ 7% O2 EPA Method 321 Down

Exhaust Stream %Moisture 26.7 25.9 26.1 %

Exhaust Flowrate 161400 164100 166000 dscfmExhaust Temperature 331 331 328 Degree FSample Date (mm/dd/yyyy)HCl Concentration ppmvd @ 7% O2

Exhaust Stream %Moisture %Exhaust Flowrate (select flowrate units)

Exhaust Temperature (select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a response
ue in dry p

 corrected 

s are below

he detectio

255 253 253

Worksheet Title: HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet? Facilities that use Method 321 to test for HCl

Company Name: Holcim (US), Inc.

Facility Name: Devils Slide Address: 6055 East Croydon RoadCity: MorganState: UtahKiln ID: Precalciner KilnKiln Type: Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill: Yes or No YESControl Device Configuration: Fabric Filter

Parameter

Sample #1

Sample #2

Sample #3

Test AverageUnits

Units Other 

DescriptionTest Method Used Test Locatio

Enter HCl concentration valper million volume (ppmvd)7% oxygen. If the test resultdetection limit, please note tlimit in brackets (e.g., [< 0.010]). 

Select appropfrom list. If otselected pleasunits in colum

arts 

to 

n 

riate unit 

her is 

e describe 

n H at right. Enter the name of the Test Method used.

Indicate whether the occurred upstream odownstream of a codevice(s); list the codevice(s)

Sample Date (mm/dd/yyyy) 2/24/2010 2/24/2010 2/24/2010

HCl Concentration 2.81 4.11 2.73 3.21 ppmvd @ 7% O2 EPA Method 321 Down 

Exhaust Stream %Moisture 12.3 10.2 10.6 % 

Exhaust Flowrate 184800 187100 188600 dscfm E hxaust Temperatur T e 255 253 253 Degree F D Sample Date (mm/dd/yyyy) 2/25/2010 2/25/2010 2/25/2010

HCl Concentration 7.59 8.22 5.44 7.08 ppmvd @ 7% O2 EPA Method 321 Down 

Exhaust Stream %Moisture 6.8 8.9 12.4 % 

Exhaust Flowrate 189900 187400 179500 dscfm 

Exhaust Temperature 302 304 302 Degree F 

Notes:Peach shaded cells indicate areas where the user will enter a response
 value in d

 (ppmvd) 

 If the test 

t, please no

ts 

Exhaust Flowrate 440300 423500 411900 dscfm Worksheet Title: HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet? Facilities that use Method 321 to test for HClCompany Name: Holcim (US), Inc.Facility Name: Saint GenevieveAddress: 2942 US Highway 61City: BloomsdaleState: MOKiln ID: PrecalcinerKiln Type: Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill: Yes or No YESControl Device Configuration: Fabric Filter and Lime Injection

Parameter

Sample #1

Sample #2

Sample #3

Test AverageUnits

Units Other 

DescriptionTest Method Used Test Loc

Enter HCl concentrationparts per million volumecorrected to 7% oxygen.are below detection limidetection limit in bracke(e.g., [< 0.010]). 

Select approfrom list. If selected pleaunits in colu

ry 

results 

te the 

priate unit 

other is 

se describe 

mn H at right. Enter the name of the Test Method used.

Indicate whetheoccurred upstreadownstream of device(s); list thdevice(s)

Sample Date (mm/dd/yyyy) 2/14/2010 2/14/2010 2/14/2010

HCl Concentration [<0.23] [<0.21] [<0.23] [<0.22] ppmvd @ 7% O2 EPA Method 321 Down 

Exhaust Stream %Moisture 12.7 12.9 12.8 % 

Exhaust Flowrate 440300 423500 411900 dscfm Exhaust Temperature 197 194 192 Degree F Sample Date (mm/dd/yyyy) 2/15/2010 2/15/2010 2/15/2010

HCl Concentration 2.38 4.14 3.62 3.38 ppmvd @ 7% O2 EPA Method 321 

Exhaust Stream %Moisture 7.4 8.1 7.3 % 

Exhaust Flowrate 428300 429600 434800 dscfm 

Exhaust Temperature 355 367 364 (select temperature units) 

Sample Date (mm/dd/yyyy) 2/15/2010 2/15/2010 2/15/2010

HCl Concentration 0.78 1.12 1.24 1.04 ppmvd @ 7% O2 EPA Method 321 

Exhaust Stream %Moisture 10.9 11.1 10.5 % 

Exhaust Flowrate 413900 404300 419100 (select flowrate units) 

Exhaust Temperature 270 272 276 (select temperature units) Notes:Peach shaded cells indicate areas where the user will enter a response
on value in

me (ppmvd

en. If the te

ction limit

ion limit in

Exhaust Flowrate (select flowrate units)Worksheet Title: HCl Emission Test Results Template Using Method 321Who Should Complete this Spreadsheet? Facilities that use Method 321 to test for HClCompany Name:

Facility Name:Address:City:

State:Kiln ID:Kiln Type: Indicate whether the kiln is wet, long dry, PH, PH/PCIn-line Raw Mill: Yes or NoControl Device Configuration: Enter all installed air pollution control devices here

Parameter

Sample #1

Sample #2

Sample #3

Test AverageUnits

Units Other 

DescriptionTest Method Used Test Locatio

Enter HCl concentratiparts per million volucorrected to 7% oxygresults are below deteplease note the detectbrackets (e.g., [< 0.010]). 

Select approprfrom list. If othselected pleaseunits in column

 dry 

) 

st 

, iate unit 

er is 

 describe 

 H at right. Enter the name of the Test Method used.

Indicate whether the occurred upstream odownstream of a condevice(s); list the codevice(s)

Sample Date (mm/dd/yyyy)HCl Concentration ppmvd @ 7% O2Exhaust Stream %Moisture %

Exhaust Flowrate (select flowrate units)Exhaust Temperature (select temperature units)Sample Date (mm/dd/yyyy)HCl Concentration ppmvd @ 7% O2

Exhaust Stream %Moisture %Exhaust Flowrate (select flowrate units)

Exhaust Temperature (select temperature units)Notes:Peach shaded cells indicate areas where the user will enter a response
DEECO Inc.

3404 Lake Woodard Road

Raleigh, NC 27604

(919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com

Site-Specific Test Plan

U.S. EPA Information Collection Request

for

Hydrogen Chloride Emissions

from

Portland Cement Manufacturing Facilities

Holcim (US) Inc. - Ste. Genevieve Plant

2942 US Highway 61

Bloomsdale, MO 63627

Submitted By:

DEECO, INC.

3404 Lake Woodard Road

Raleigh, NC 27603

February 10, 2010

Proposed Test Date: February 13-15, 2010
TABLE OF CONTENTS

Section Page

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Test Program Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

2.0 SOURCE DESCRIPTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

3.0 TEST PROGRAM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.1 Objectives . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.2 Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5

3.3 PROCESS PERFORMANCE INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

3.4 Test Coordination . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

4.0 SAMPLING LOCATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

4.1 Flue Gas Sampling Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

5.0 SAMPLING AND ANALYTICAL PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.1 Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.2 Sampling Point Determination - EPA Method 1 . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2 . . . . . . . . . . . . . 11

5.4 Outlet Flue Gas Composition - EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . 11

5.5 Flue Gas Moisture Content - EPA Method 4 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

5.6.1 Test Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

5.6.2 Conditioning and Operational Test Periods . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.3 Test Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.4 Test Procedures for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

5.6.4 Calibration Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

5.6.5 Test Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

5.6.6 Data Acquisition . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

5.7 Test Procedures for EPA Method 321 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

6.0 QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1 QC PROCEDURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1.1 Manual Sampling Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1.2 Manual Sampling Equipment Calibration . . . . . . . . . . . . . . . . . . . . . . . . 18

6.1.3 Manual Sampling Quality Control Procedures . . . . . . . . . . . . . . . . . . . . 23

7.0 REPORTING AND DATA REDUCTION REQUIREMENTS . . . . . . . . . . . . . . . . . . . . . . 26

Format . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

7.2 Data Reduction and Summary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27
TABLE OF CONTENTS (continuerd)

Section Page

8.0 PLANT ENTRY AND SAFETY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

8.1 Safety Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

8.2 Safety Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

8.3 Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 28

9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE . . . . . . . . . . . . . . . . . . . . . 29

9.1 Test Site Organization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

9.2 Test Preparations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29

9.3 Test Personnel Responsibilities and Detailed Schedule . . . . . . . . . . . . . . . . . . . 29

LIST OF TABLES

Table Page

TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS . . . . . . 6

TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE . . . . . . . . . . . . . 8

TABLE 6.1 SUMMARY QA/QC ACTIVITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLORIDE

EMISSION TEST RESULTS, HOLCIM (US) SAINT GENEVIEVE FACILITY,

BOTH RAW MILLS OFF CONDITION; FEBRUARY 15, 2010 . . . . . . . . . . . 27

LIST OF FIGURES

Figure Page

Figure 1.1 Organization for Holcim (US) Inc. Saint Genevieve Facility HCl ICR Test Program

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Figure 4.1 Schematic of the Main Kiln/Raw Mill Stack sampling location . . . . . . . . . . . . . . . . 10

Figure 6.1 Example field data sheet for EPA Methods 2 and 4 . . . . . . . . . . . . . . . . . . . . . . . . . 19

Figure 6.2 Example field data sheet for EPA Method 3A . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
HCl ICR Site-Specific Test Protocol Page: 1

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

1.0 INTRODUCTION

1.1 Summary of Test Program

The U.S. Environmental Protection Agency (EPA), Office of Air Quality Planning and

Standards (OAQPS) has issued an Information Collection Request (ICR) to Holcim (US), Inc

(Holcim). Under the authority of Section 114 of the Clean Air Act (CAA). The EPA is requesting

information on hydrogen chloride (HCl) emissions from nonhazardous waste-burning kilns at

Portland cement manufacturing facilities. This request is in response to comments from Portland

cement industry members and its trade association to EPA’s proposal to amend the national emission

standards for hazardous air pollutants for Portland cement manufacturing (74 FR 21136 (May 6,

2009)).

Holcim has retained DEECO Inc. (DEECO) to conduct the required emissions testing.

Testing for HCl will be conducted in accordance with EPA Method 321 - Measurement of Gaseous

Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared (FTIR)

Spectroscopy. 

The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and

26A) may have positive biases due to chloride salts (such as ammonium chloride) that, when

collected in the sampling train, for chloride ions (Cl-

) that is indistinguishable from the Cl- ion

formed upon collection of HCl. In addition, a negative bias may also exist due to condensation

and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has

decided that the FTIR measurement by EPA Method 321 is the preferred technique for determining

the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement

manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/portland.pdf).

The Holcim facility located east of the township of Danby in Ste. Genevieve County

(designated as the Ste. Genevieve plant with the physical address of 2942 US Highway 61

Bloomsdale, MO 63627) has been one of the Portland cement manufacturing facilities selected as

part of the ICR. The source is identified as Cement Kiln/Raw Mill Stack (421/2-BF1).

HCl emission tests will be conducted at the main kiln/raw mill stack during three conditions;

both raw mills on (Mill On/On), one raw mill off (Mill Off/On) and both raw mills off (Mill

Off/Off). 

Testing is anticipated to be conducted February 12-14, 2010.

1.2 Test Program Organization

Figure 1.1 presents the test program organization, major lines of communication, and names

and phone numbers of responsible individuals.
HCl ICR Site-Specific Test Protocol Page: 2

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

EPA OAQPS, Sector Policies and

Programs Division

Peter Tsirigotis

Research Triangle Institute

Contract EP -D-06-118

EPA Sector Policies and

Programs Division

Keith Barnett

(919)541-5605

Barnett.Keitht@epa.gov

Holcim (US), Inc.

Corporate Contacts

Ruksana Mirza

or 

Hector Ybanez

Corporate Manager,

Environmental

(214) 524 - 2814

Hector.Ybanez@holcim.com

Holcim (US), Inc.

Environmental Contact

Timothy Schlosser

(734)529-4118

Timothy.Schlosser@holcim.com

EPA report data

contact

Ron Meyers 

(919) 541-5407

myers.ron@epa.gov

or 

Barrett Parker 

(919) 541-5635

parker.barrett@epa.gov

Holcim (US) Inc.

Ste. Genevieve Plant

Mr. James Lunan

(636) 524-8184

James.Lunan@holcim.com

EPA Test Method contact

Peter Westlin

(919) 541-1058

westlin.peter@epa.gov

or

Gary McAllister 

(919) 541-1062

mcalister.gary@epa.gov

DEECO Project Manager

Scott Steinsberger

(919)250-0285

deeco@deeco.com

DEECO Field Team

Figure 1.1 Organization for Holcim (US) Inc. Saint Genevieve Facility HCl ICR Test Program
HCl ICR Site-Specific Test Protocol Page: 3

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

2.0 SOURCE DESCRIPTION

2.1 Process Description

The Ste. Genevieve plant has the annual clinker production capacity of 4,828,074 tons with

a Portland cement production capacity of 5,082,183 tons. Operational units that accommodate this

level of production include an on-site quarry, raw material storage, crushing and milling, solid fuel

(coal and petroleum coke) storage and milling, liquid fuel storage, one preheater/precalciner cement

kiln system, product milling, product storage, and loading and unloading systems.

Cement manufacturing involves chemical and physical processing of large quantities of raw

materials. The raw materials used include sources of calcium, silica, alumina and iron. These are

the components necessary for the manufacture of the cement chemicals dicalcium silicate, tricalcium

silicate, tricalcium aluminate, and tetra-calcium aluminoferrite. The raw feed is prepared for use in

the kiln system by sizing, grinding and blending the various raw materials to produce the necessary

mix for quality production. The prepared raw feed is introduced to the kiln system where it is

physically and chemically transformed into clinker, the intermediate product of Portland cement.

In the kiln system, the raw materials are exposed to temperatures reaching up to 3,500EF through a

countercurrent process in the kiln and a co-current process in the preheater. The raw materials are

heated to 2,650EF, the temperature required to produce quality clinker. Both on-site and off-site

sources supply raw materials for cement kiln feed at the Ste. Genevieve plant. Quarry resources

include limestone and shale deposits that will comprise part of the raw material blend to become

clinker, the principal product. Holcim will receive other raw materials from off-site suppliers at the

Ste. Genevieve plant by rail, truck, and barge via the Mississippi River. Materials received from offsite may include limestone, iron ore, clay, bottom ash, fly ash, bauxite, diaspore, gypsum and other

materials as necessary. An important source of raw materials is nonhazardous waste materials from

other industries that have the proper chemical and physical properties to be used as a raw material

source. The Ste. Genevieve plant is designed for these types of materials as sources of calcium,

silica, alumina and iron. Preparation of raw materials, depending on its source and physical

properties, involves primary and secondary crushing, and screening, blending and grinding in the raw

mills prior to entrance into the preheater tower of the cement kiln system.

Holcim uses coal and petroleum coke as the primary fuels for the cement manufacturing

process at the Ste. Genevieve plant. Holcim uses coal mills to prepare raw coal/coke for firing in

the precalciner and the kiln. Solid fuels are received at the facility by truck, rail, and river barge.

Liquid oils and similar non-hazardous materials are used as a secondary fuel in critical situations

such as start-up and back-up. The facility’s equipment design also allows Holcim to beneficially use

many other sources of energy bearing, non-hazardous waste materials as supplemental fuel, such as

whole or shredded tires, when available. The preheater/precalciner pyroprocess is a state-of-the-art

design that features five-stage cyclone-type preheater tower, low-NOx precalciner, and a rotary kiln.

The preheater/precalciner portion of the system is located in a tall tower adjacent to the kiln. The

low-NOx precalciner will be located at the base of the tower. The precalciner allows the burning fuel

to be thoroughly mixed with the kiln feed. Excess heated air from the clinker cooler (tertiary air) will

provide combustion air for the precalciner. Preheater/precalciner kilns feature greater thermal

efficiency as compared to long dry or long wet kilns. This results in significantly lower emissions

and decreased fuel consumption per ton of clinker produced. To increase energy efficiency even
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further, hot exhaust gases from the preheater tower are utilized to dry kiln feed in the raw mills and

fuel in the coal mill.

2.2 Control Equipment Description

The emissions from the kiln are controlled by fabric filter baghouses. In addition lime

injection is used for additional acid gas control.
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3.0 TEST PROGRAM

3.1 Objectives

Testing for HCl will be conducted in accordance with EPA Method 321 - Measurement of

Gaseous Hydrogen Chloride Emissions At Portland Cement Kilns by Fourier Transform Infrared

(FTIR) Spectroscopy. 

The EPA has recognized that the manual sampling techniques for HCl (EPA Methods 26 and

26A) may have positive biases due to chloride salts (such as ammonium chloride) that, when

collected in the sampling train, for chloride ions (Cl-

) that is indistinguishable from the Cl- ion

formed upon collection of HCl. In addition, a negative bias may also exist due to condensation

and/or removal of HCl on the filter and/or in the sampling probe. Consequently, the EPA has

decided that the FTIR measurement by EPA Method 321 is the preferred technique for determining

the concentration of HCl emissions from nonhazardous waste-burning kilns at Portland cement

manufacturing facilities (Source http://www.epa.gov/ttn/atw/pcem/portland.pdf).

The specific objectives in order of priority are:

C Measure the emissions of HCl (EPA Method 321) from the Cement Kiln/Raw Mill Stack

during three conditions; both raw mills on (Mill On/On), one raw mill off (Mill Off/On) and

both raw mills off (Mill Off/Off), and

C Concurrent with the HCl measurements, measure the Cement Kiln/Raw Mill Stack

volumetric flow rate (EPA Methods 1 and 2), the Cement Kiln/Raw Mill Stack oxygen and

carbon dioxide content (EPA Method3A), and the Cement Kiln/Raw Mill Stack moisture

content.

Relevant process information will be collected by plant personnel in conjunction with the

testing program. The raw process data will be presented as collected in the appendices of the final

report.

3.2 Test Matrix

Table 3.1 presents the sampling and analytical matrix.
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TABLE 3.1 SUMMARY OF SAMPLING AND ANALYTICAL TEST METHODS

Test

Parameter

Sampling

Method Sample Type

Sampling

Frequency Analytical Method

Measurement

Technique

Volumetric

Flow Rate

EPA Methods

1 and 2

Traverse points;

thermocouple

and Pitot tube

Concurrent

with each

Method 321

test

EPA Method 2

(40 CFR 60, App A)

Thermocouple

readout and 

manometer

Oxygen and 

Carbon

Dioxide

EPA Method

3A

Extractive

instrumental

sample

Concurrent

with each 

Method 321

test

EPA Method 3A

(40 CFR 60, App A)

Paramagnetic

for O2 and

NDIR for CO2

Moisture EPA Method

4

Traverse points;

Condensation

Concurrent

with each 

Method 321

test

EPA Method 4

(40 CFR 60, App A) Gravimetric

Hydrogen

Chloride

EPA Method

321

Extractive

instrumental

sample

Three 60-

minute

test runs per

condition

EPA Method 321

(40 CFR 63, App A)

Fourier

Transform

Infrared

(FTIR)

spectrometry 
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3.3 PROCESS PERFORMANCE INFORMATION

Plant personnel in conjunction with the testing program will collect process information. The

raw process data will be presented as collected in the appendices of the final report.

3.4 Test Coordination

Mr. James Lunan, the Holcim facility contact, will serve as the test coordinator. He will be

responsible for:

1. Scheduling the start of all testing;

2. Principal contact with the agency officials concerning the tests;

3. Principal contact with DEECO concerning the tests;

4. Recording the process data during the testing; and 

5. Providing copies of any field test data to the agency.

A tentative test schedule is shown in table 3.2.
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TABLE 3.2 PROGRAM OUTLINE AND TENTATIVE TEST SCHEDULE

Sampling Location Parameter(s)

Measured

Sampling

Method

Number of Runs

and Duration

Length of

Day(s)

Day 1 - February 13, 2010 Arrive on-site and set up test equipment 8 hours

Days 2 & 3 - February 14-15, 2010

Kiln Stack Flue Gas Flowrate EPA Methods 1, 2, 4 Three 60-minute

runs per condition

(Mill On/On, Mill

On/Off, and Mill

Off/Off)

10 hours

O2/CO2 EPA Method 3A

HCl EPA Method 321

Day 4 - February 16, 2010 Contingency Day
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4.0 SAMPLING LOCATIONS

4.1 Flue Gas Sampling Location

The kiln/raw mill stack is a vertically-oriented circular stack with an inside diameter of

approximately 219". The stack gas sampling ports are located approximately 146.7' (approximately

8.0 duct diameters) above the closest disturbance and approximately 147.3' (approximately 8.1 duct

diameters) from the stack outlet. The sampling location meets the minimum specifications for

selection of a measurement site as outlined in EPA Method 1.

A schematic of the Main Kiln/Raw Mill Stack sampling location is shown in Figure 4.1
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Figure 4.1 Schematic of the Main Kiln/Raw Mill Stack sampling location.
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5.0 SAMPLING AND ANALYTICAL PROCEDURES

5.1 Test Methods

This section contains a brief description of the sampling and analytical procedures for each

method that will be employed during the test program. All equipment, procedures, and quality

assurance measures necessary for completion of the test program will meet or exceed the

specifications of the appropriate methods. Any deviations from the methods to ensure quality

representativeness of the results are also discussed.

5.2 Sampling Point Determination - EPA Method 1

The number and location of the sampling or traverse points will be determined according to

the procedures outlined in EPA Method 1. The sample location has already been confirmed to meet

EPA Method 1 based on previous source tests. All points will be at least 1.0 inches from the stack

wall, per Method 1. For the main kiln stack, a total of 12 velocity/isokinetic traverse points will be

used, with six points on each of the two 90o axes

5.3 Flue Gas Velocity and Volumetric Flow Rate - EPA Method 2

The flue gas velocity and volumetric flow rate will be determined according to the procedures

outlined in EPA Method 2. Velocity measurements will be made using type S pitot tubes conforming

to the calibration specifications outlined in EPA Method 2, Section 10.1. Each Type-S pitot tube,

calibrated according to these standards, will have an assigned coefficient. Differential pressures will

be measured with Magnehelic gauges of appropriate range or with fluid manometers. Effluent gas

temperatures will be measured with chromel-alumel thermocouples equipped with digital readouts.

5.4 Outlet Flue Gas Composition - EPA Method 3A

Outlet flue gas analysis for oxygen (O2

) and carbon dioxide (CO2) concentrations, and the

calculation of percent excess air and flue gas dry molecular weight will be performed in accordance

with EPA Method 3A. Refer to Section 5.6 for more information

5.5 Flue Gas Moisture Content - EPA Method 4

The flue gas moisture content will be determined in conjunction with each sampling run and

according to the sampling and analytical procedures outlined in EPA Method 4. The impingers will

be connected in series, and contained in an ice bath in order to assure condensation of the moisture

in the flue gas stream. Any moisture that is not condensed in the impingers is captured in the silica

gel, therefore all moisture can be weighed and entered into moisture content calculations.
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5.6 Oxygen, Carbon Dioxide, and Hydrogen Chloride - EPA Methods 3A and 321

A CEM system will be used to determine oxygen and carbon dioxide concentrations and

hydrogen chloride concentrations on the Main Kiln/Raw Mill stack. The procedures used in meeting

these requirements are detailed below.

5.6.1 Test Equipment Description

The instrumentation and all sampling and analytical procedures that will be used by DEECO

for the HCl ICR testing will conform with the requirements of EPA Test Methods 3A and 321 using

FTIR.

For HCl, the extractive system requires that the effluent gas sample be filtered and maintained

at a minimum of 356°F (180°C) prior to being delivered to the FTIR sample cell. The FTIR sample

cell will also be maintained at 356°F. The gas sample will be drawn through the extractive system

and the FTIR cell using a heated sample pump. The extractive system will be equipped with a glass

lined probe also heated to a minimum of 356°F. The probe will be of sufficient length to reach a

minimum of three traverse points at 17, 50, and 83 percent of the duct diameter or 0.4, 1.2, and 2.0

meters from the stack or duct wall, which ever is less. All components of the sampling system which

contact the sample will be either of glass, stainless steel, or Teflon

The extracted gas sample exiting the heated sample pump will be conditioned to remove

moisture with an ice water-cooled condenser. A gas distribution manifold will be used to deliver a

representative sample of flue gas to oxygen and carbon dioxide analyzers.

Fourier Transform Infrared (FTIR) spectroscopy for Hydrogen Chloride - FTIR spectroscopy

measures vapor phase organic or inorganic compounds which absorb energy in the mid-infrared

spectral region, about 400 to 4000 cm-1 (25 to 2.5 μm). Continuous measurement is made by

matching sample absorbance bands with bands in reference spectra, and comparing sample band

intensities with reference band intensities.

The principle limitation to FTIR spectroscopy are the presence of interfering compounds that

also absorb energy in the mid-infrared spectral region. In a cement kiln stack gas matrix, water vapor

(H2O) and carbon dioxide (CO2

) are the primary interferents that must be incorporated into the

identification and quantitation method.

By choosing the proper analytical region(s) for the HCl spectra, the effect of the interfering

compounds can be minimized. The analytical regions will be selected based on examination of the

actual stack gas matrix. (It should be noted that the analytical region provided as an example in EPA

Method 321 (2679-2840 cm-1) does not correspond with the entire analytical region for HCl (2600-

3100 cm-1). The example cited in Method 321 appears to have been copied from the formaldehyde

analytical region used as an example in Method 318.)

The FTIR software performs the computation for a single compound by subtracting all the

other compounds (interferants and target) from the absorbance spectra and quantifies the single

compound based on the remain absorbance. The FTIR software provides a Standard Error

Calculation (SEC) value that is an indication of how well the identification and quantitation has been

performed. A high SEC indicates that other interferants have not been accounted for in the analysis
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method, and a low SEC is indicative of greater confidence mesurement. Typically, if the reported

SEC is greater than half the reported concentration then the results is suspect. 

A MIDAC I-Series FTIR will be used to determine HCl concentrations according to EPA

Method 321. Infrared absorption spectroscopy is performed by directing an infrared beam through

a sample to a detector. The frequency-dependent infrared absorbance of the sample is measured by

comparing this detector signal (single beam spectrum) to a signal obtained without a sample in the

beam path (background). Most molecules absorb infrared radiation and the absorbance occurs in a

characteristic and reproducible pattern. The infrared spectrum measures fundamental molecular

properties and a compound can be identified from its infrared spectrum alone. Within constraints,

there is a linear relationship between infrared absorption and compound concentration. If this

frequency dependent relationship (absorptivity) is known (measured), it can be used to determine

compound concentration in a sample mixture.

Absorptivity is measured by preparing, in the laboratory, standard samples of compounds at

known concentrations and measuring the FTIR "reference spectra" of these standard samples. These

"reference spectra" are then used in sample analysis: (1) compounds are detected by matching sample

absorbance bands with bands in reference spectra, and (2) concentrations are measured by comparing

sample band intensities with reference band intensities.

Reference spectra for hydrogen chloride and sulfur hexafluoride will be generated from

commercially-available calibration gas cylinders. The EPA reference spectra available from the

EPA’s Emission Measurement Center are not representative of the concentrations (at 189.5 ppmmeters and 497.3 ppm-meters) being measured. HCl reference spectra at 2 ppm and 5 ppm (16.3

ppm-meters and 40.8 ppm-meters) will be used. Secondly, higher resolution spectra, compared to

the EPA reference spectra, will be necessary due to the low HCl concentrations that are expected and

the high moisture levels (up to 35%) that will be encountered. Thirdly, errors have been reported for

certain EPA reference spectra, so the entire EPA reference spectra data base should be suspect.

CAI Model 200 O2

/CO2 Analyzer - The CAI Model 200 O2/CO2 analyzer houses two measurement

principles in one instrument. The oxygen concentrations are measured using the parapneumatic

technique. Because of its sp3 electron orbital distribution, an oxygen molecule has an unpaired

electron and hence displays a magnetic orientation. Since other elements that display this magnetic

phenomenon are not common gasses at normal temperatures, the parapneumatic measurement

technique is virtually specific for oxygen. The sample gas flows through a detection cell located in

a very strong magnetic field. The magnetic nature of the oxygen causes the oxygen to move to one

side of the detection cell, inducing a pressure differential proportional to the oxygen concentration

in the detector cell. The analyzer measures this pressure differential, converts the pressure differential

to an electrical signal, and sends the results as output.

The carbon dioxide concentrations are measured using a single-beam photometric system with

a micro flow sensor detector. The micro flow detector is a sealed unit filled with carbon dioxide.The

instrument consists of an infrared light source, a chopper, a measuring cell and a micro flow detector

filled with carbon dioxide. The infrared light emitted backward is reflected by a reflecting surface

and is added to the infrared light emitted forward. Arranged between the infrared light source and

the measuring cell is a chopper blade which rotates to modulate the infrared light beam at regular

frequency. The modulated infrared light beam thus formed passes through the measuring cell filled

with a sample gas where the light energy is partially absorbed or attenuated before it reaches the front
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chamber of the detector. Both the front and rear chambers of the detector are filled with the gas

component to be measured. The infrared light energy is partially absorbed in the front chamber and

residual light is absorbed in the rear chamber, thereby increasing the pressure in both chambers.

Since the detector is designed to produce a pressure difference between the front and rear chambers,

a slight gas flow is produced through a path connecting these chambers with each other. This slight

flow is converted into an AC electrical signal by a micro flow sensor.

5.6.2 Conditioning and Operational Test Periods 

The conditioning and operational test periods will be completed and sampling commenced

once all monitors are found to be acceptable.

5.6.3 Test Requirements

DEECO's extractive measurement system and all sampling and analytical procedures for

testing will conform to the requirements of EPA Methods 2, 3A, and 4 of 40 CFR 60 and EPA

Method 321 of 40 CFR 63.

The extractive monitors require that the effluent gas sample be conditioned to eliminate any

possible interference (water vapor and particulate matter) before being transported and injected into

each analyzer. All components of the sampling system that contact the sample are Type 316 stainless

steel, glass, or Teflon.

A heated probe with an in-stack particulate filter, heated sample lines, moisture removal trap,

a sample pump, and distribution manifold board are used to deliver a representative sample of flue

gas to the analyzers. The sampling probes are constructed of 316 stainless steel and are heated

electrically to maintain the sample temperature above the dew point. 

The sample acquisition and conditioning system also includes two injection ports: (1)

immediately upstream of the analyzers for analyzer linearity checks, and (2) at the outlet of the probe

for the sampling system bias and calibration drift checks. This arrangement provides both ease in

checking the analyzer performance and a means of evaluating the entire monitoring system.

5.6.4 Test Procedures for EPA Method 3A

All analyzers will be subjected to an interference check similar to the procedures in Section

5.4 of EPA Method 20. During calibration, all analyzers’ response will be noted while introducing

each calibration gas. If the sum of the interference responses of the test gases for any of the analyzers

is greater than 2 percent of the applicable span value, corrective measures on the analyzer will be

taken, up to and including replacement of the analyzer.

Calibration procedures will be performed in accordance with EPA methodology. Analyzers

will be calibrated before and after each test and a calibration check will be done between each test

run.
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The pretest calibrations will consist of the following steps:

• Internal (direct) calibration of each analyzer to adjust calibration and check linearity.

• External (through the entire sampling system) calibration to check the system bias on

zero and span gases.

The post test calibration will consist of an external system bias calibration check.

5.6.4.1 Internal Calibration - Each analyzer will be calibrated using a certified zero and span (mid

or high range as necessary) gas. Zero and span gases will be directed to each analyzer through the

appropriate plumbing, the calibration gas flow rates will be adjusted to the correct flow rate and the

analyzer will be adjusted with the appropriate span pot. After the analyzer is properly adjusted the

linearity will be checked using a mid range calibration gas. The maximum allowable limit for

linearity is 2% of the analyzer range. All analyzers will be shown to be linear within these limits

before proceeding.

5.6.3.2 External Calibration - The external calibration bias check will be performed by placing the

CEM system in the sampling mode and injecting a zero and span gas into the sample line at the probe

exit. This check will show if there was any sampling system related bias, and also served as a check

of the integrity of the sample line.

5.6.4 Calibration Gases

DEECO will use EPA Protocol #1 gases for calibration as required by the various reference

methods used in this test program. Calibration gases will be selected from previous experience with

similar sources and/or from information obtained from the facility engineer prior to sampling. Audit

gases, if available from federal or state agencies, will be analyzed.

5.6.5 Test Procedures

At the completion of the pretest calibration routine, the CEM system will be ready for

operation. No further adjustments of sample flow rates, analyzer zero or span adjustments, or other

critical CEM operating parameters will be made until testing and post test calibration are complete.

The CEMs will be allowed to at least 21 minutes to complete each test run. At the completion for

each run, calibration gases nearest to the measured emission levels will be used to check each

instrument.

During each sampling run, a sampling traverse will be performed to ensure the absence of

stratification. Traverse points will be selected that assure acquisition of representative samples over

the stack or duct cross section. A minimum requirement is the establishment of a "measurement line"

that passes through the centroidal area and in the direction of any expected stratification. If this line

interferes with the CEM measurements, the line will be displaced up to 30 cm (12 in.) (or 5 percent

of the equivalent diameter of the cross section, whichever is less) from the centroidal area. Per

Section 6.5.6.3(a) of 40 CFR 75, three traverse points will be located 16.7, 50.0, and 83.3 percent of

the measurement line, and measured equally during each run. Alternatively, per Section 6.5.6.3(b)

of 40 CFR 75, a single sampling point may be used if the concentration of each compound at each

individual traverse point differs by no more than ±5.0 percent from the arithmetic average

concentration for all traverse points.
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Concurrent measurements of flow following EPA Methods 1, 2, 3A, and 4 (Sections 5.1

through 5.5) will be used to determine flue gas emission rates of all target compounds.

5.6.6 Data Acquisition

Data will be recorded on two separate devices. A hard copy will be obtained using a Molytek

2702 strip chart recorder. Data will also be recorded to the hard disk of an IBM compatible computer

utilizing the serial output of the Molytek recorder in conjunction with custom software. Data for each

of the analyzers will be sampled each second with a one-minute average being written to disk. Data

will be further averaged over the test period and corrected for calibration error and drift using a

spreadsheet program.

5.7 Test Procedures for EPA Method 321

The FTIR optics and sample cell will be purged with nitrogen overnight. A backgroung

spectra will be collected will purging nitrogen thorough the cell at a flow rate low enough that the cell

pressure is not elevated above ambient pressure. Next an ethylene Calibration Transfer Standard

(CTS) will be passed thorough the cell, again at a flow rate low enough that the cell pressure is not

elevated above ambient pressure, and spectra will be collected of the CTS gas. By setting the cell

pressure in the software to reflect the ambient pressure, the path length can be verified and adjusted

as needed. 

As part of the HCl analyte spiking procedure, the calibration gas mixture containing HCl and

sulfur hexafluoride (SF6

) will then be passed directly to the cell, again at a flow rate low enough that

the cell pressure is not elevated above ambient pressure. This will establish the undiluted

concentration of the HCl/SF6 mixture to be used in the analyte spike recovery calculations.

Next the heated sample line will be connected directly to the sample cell, and stack gas will

be drawn through the cell prior to the pretest analyte spiking.

The first step in the analyte spiking will be to send the CTS to the sample probe and back

through the sampling system. Spectra of the CTS gas will be collected and the cell pressure setting

in the software will be adjusted as needed to provide the correct CTS reading.

After the CTS check is completed, stack gas will again be sampled to provide a pre-spike

native concentration of HCl.

Next the HCl/SF6

 gas mixture will be directed to the sample probe at a flow rate

approximately 10% of the total sample rate such that the stack gas provides a nominal 10-fold dilution

of the analyte spike. Once a satisfactory spike recovery of 70%-130% has been is achieved, the

HCl/SF6 gas mixture will be turned off. The HCl/SF6 spike will be purged from the system and

additional spectra will be collected from the stack gas to determine the post spike concentration of

the native HCl.
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It should be noted that there are errors in the Method 321 equation used to calculate the

analyte spike recovery. Consequently the following correct equation will be used;

%R

C C

DF

C

DF

t n

s

=

− −













×

×

1

1

1

100

%R = Spike Recovery

Ct = Concentration of the total HCl (spike plus native), ppm,

Cn = Average concentration of the native HCl (pre and post spike), ppm,

Cs = Concentration of the HCl spike, ppm; and

DF = Ratio of the undiluted SF6

 tracer gas concentration to the diluted SF6 measured during

analyte spiking 
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6.0 QA/QC ACTIVITIES

6.1 QC PROCEDURES

Example data sheets for EPA Methods 2 and 4 and EPA Method 3A are provided in Figures

6.1 and 6.2.

Specific QA/QC parameters for each method is provided in Table 6.1 and described in detail

below.

6.1.1 Manual Sampling Equipment

Each item of field test equipment will be assigned a unique, permanent identification number.

An effective preventative maintenance program is necessary to ensure data quality. Each item of

equipment returning from the field will be inspected before it is returned to storage. During the

course of these inspections, items are cleaned, repaired, reconditioned, and recalibrated where

necessary.

Each item of equipment transported to the field for this test program will be inspected again

before being packed to detect equipment problems which may originate during periods of storage.

This minimizes lost time on the job site due to equipment failure.

Occasional equipment failure in the field is unavoidable despite the most rigorous inspection

and maintenance procedures. For this reason, replacement equipment for all critical sampling train

components will be transported to the job site.

6.1.2 Manual Sampling Equipment Calibration

New items for which calibration is required will be calibrated before initial field use.

Equipment whose calibration status may change with use or time will be inspected in the field before

testing begins and again upon return from each field use. When an item of equipment is found to be

out of calibration, it will be repaired and recalibrated or retired from service. All equipment will be

periodically recalibrated in full, regardless of the outcome of these regular inspections.

Calibrations will be conducted in a manner, and at a frequency, which meets or exceeds U.S.

EPA specifications. The calibration procedures outlined in the EPA Methods will be followed.

When these methods are inapplicable, methods such as those prescribed by the American Society for

Testing Materials (ASTM) will be used.

Data obtained during calibrations will be recorded on standardized forms, which will be

checked for completeness and accuracy by the quality assurance manager. Data reduction and

subsequent calculations will be performed using computer facilities. Calculations will be checked

at least twice for accuracy. Copies of calibration forms will be included in the final test report.

Emissions sampling equipment requiring calibration includes pitot tubes, pressure gauges,

thermometers, dry gas meters and barometers. The following sections elaborate on the calibration

procedures to be followed for these items of equipment.
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Flow rate and Moisture Measurement Data Sheet

Plant and City Date Sampling Location Sample Type Run No.

Operator

Barometric

Pressure

(Pb)

(In. Hg)

Static

Press

(in. H2O)

Ambient

Temp

(deg. F)

Stack

ID

(In.)

Pitot

Cp

DGM

Box No.

DGM

delta H@

DGM Cal

Factor

(gamma)

Probe

 ID

No.

EPA Method 3/3A Data EPA Method 4 Impinger Weights

Oxygen, % Impinger 1 2 3 Sil.Gel

Carbon Dioxide, % Final Wt., g Color

Nitrogen, % Initial Wt., g % Spent

Net Wt., g

Total Collected , g

EPA Method 2 Data EPA Method 4 Sampling Data

Run Time

(24 hr)

Port/Point

ID 

Pitot

delta P

(in. H2O)

Stack

Temp

(deg. F)

Run Time

(24 hr)

DGM

Reading

(cu.ft.)

DGM

delta H 

(in. H2O)

DGM

Temps

(deg. F)

Exit

Temp

(deg. F)

Sample

Train Vac.

(In. Hg)

Initial Leak Rate cfm @ “Hg

Final Leak Rate cfm @ “Hg

Pitot Leak Check

Figure 6.1 Example field data sheet for EPA Methods 2 and 4
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Plant and City Test Location Date Operator

Cylinder

ID

Gas

Type Value

Internal

Response

Cal

Error

Run No. Run Time

Pre Run

Bias

Percent

Bias

Post Run

Bias

Percent

Bias

Percent

Drift

O2 Zero Zero N2

CC5134 O2 Mid 11.9%

CC117302 O2 Span 21.9%

CO2 Zero Zero N2

CC5134 CO2 Mid 20.4%

CC117302 CO2 Span 35.5%

Figure 6.2 Example field data sheet for EPA Method 3A
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TABLE 6.1 SUMMARY QA/QC ACTIVITIES

Test Equipment QC Parameter Target

Volumetric Flow Rate Measurement

Pitot Tube Pitot Geometry Within Specifications

Thermocouple <1.5% absolute

Pitot Leak Check stable 15 sec at $4 in. WC

Dry Gas Meters for Particulate Sampling

Dry Gas Meters Initial Calibration 0.95 # γ # 1.05 

individual γ RSD # 2%

Post Test Calibration Check Post test γ # 5%

Post Test Leak Checks <2% of sample rate 

EPA Method 3A

Initial Calibration Zero Gas <2% of Span Gas

Mid Range Gas <2% of Span Gas

Span Gas <2% of Span Gas

Bias Checks Zero Gas <5% of Span Gas

Mid Range Gas <5% of Span Gas

Drift Zero Gas <5% of Span Gas

Mid Range Gas <5% of Span Gas

Method 321 for Hydrogen Chloride

Pre/Post CTS Calibration Precision Pre and post quantification #5% RSD

Direct HCl Calibration Precision Duplicate measurement #5% RSD

HCl Analyte Spike System Validation Spike Recovery 70% - 130%
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A: Pitot Tubes. All Type S pitot tubes used, whether separate or attached to a sampling

probe, will be constructed in-house or by a third-party vendor. Each new pitot will be

calibrated in accordance with Section 10.1 of EPA Method 2. Each Type-S pitot tube,

calibrated according to these standards, will have an assigned coefficient. This

coefficient should not change as long as the pitot tube is not damaged.

 

 Each pitot tube will be inspected visually upon return from the field. If a cursory

inspection indicates damage or raises doubt that the pitot remains in accordance with

the EPA geometry standards, the pitot tube will be refurbished as needed and

recalibrated.

B: Differential Pressure Gauge. All meter consoles used are equipped with 10-inch

water column (W.C.) inclined-vertical manometers. Fluid manometers do not require

calibration other than leak checks. Manometers will be leak checked in the field prior

to each test series, and again upon return from the field.

C: Impinger Thermometer. Prior to the start of testing, the thermocouple used to

monitor the temperature of the gas leaving the last impinger will be compared with a

mercury-in-glass thermometer which meets ASTM E-1 No. 63F specifications. The

impinger thermocouple is replaced if it does not agree within 2EF of the reference

thermometer. After each field use, the thermocouple will be checked per EPA Alt-011

procedures.

D: Dry Gas Meter Thermometer. The thermocouple used to measure the temperature

of the metered gas sample will be checked prior to initial field use against an ASTM

mercury-in-glass thermometer. The dry gas meter thermocouple is acceptable if the

values agree within ±2EF. Thermocouples not meeting this requirement will be

replaced. After each field use, the thermocouple will be checked per EPA Alt-0011

procedures.

E: Flue Gas Temperature Sensor. All thermocouples employed for the measurement

of flue gas temperature are calibrated upon receipt. Initial calibrations will be

performed at three points (ice bath, boiling water, and hot oil). An ASTM mercury-inglass thermometer will be used as a reference. The thermocouple is acceptable if the

agreement is within 1.5 percent (absolute) at each of the three calibration points.

After each field use, the thermocouple will be checked per EPA Alt-011 procedures.

Before each field use, the reading from the flue gas thermocouple-potentiometer

combination will be compared with an ASTM mercury-in-glass reference

thermometer at ambient conditions. If the two agree within ±1.5 percent (absolute),

the thermocouple and potentiometer are considered to be in proper working order.

F: Dry Gas Meter and Orifice. Two procedures will be used to calibrate the dry gas

meter and orifice simultaneously. The full calibration will be a complete laboratory

procedure used to obtain the calibration factor of the dry gas meter. Full calibrations

will be performed over a wide range of orifice settings. A simpler procedure, the posttest calibration, will be designed to check whether the calibration factor has changed.
HCl ICR Site-Specific Test Protocol Page: 23

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

A dry gas meter that is calibrated annually against a spirometer or a set of calibrated

critical orifices will be used as a transfer standard. During the annual calibration,

triplicate calibration runs will be performed at seven flow rates ranging from 0.25 to

1.40 cfm.

G: Dry Gas Meter. Each metering system receives a full calibration at the time of

purchase and a post-test calibration after each field use. If the calibration factor, γ,

deviates by less than five percent from the initial value, the test data are acceptable.

If γ deviates by more than 5 percent, the meter is recalibrated and the meter coefficient

(initial or recalibrated) that yields the lowest sample volume for the test runs is used.

EPA Method 5 requires another full calibration anytime the post-test calibration check

indicates that γ changed by more than 5 percent. Standard practice is to adjust and

recalibrate the dry gas meter anytime γ is found to be outside the range of 0.96 to 1.04.

Post-test calibrations will be performed after each field test series per EPA Alt-009

procedures.

H: Orifice. An orifice calibration factor will be calculated for each flow setting during

a full calibration. If the range of values does not vary by more than 0.15 in H2O over

the range of 0.5 to 4.0 in H2O, the arithmetic average of the values obtained during the

calibration is used.

I: Barometer. Each field barometer will be adjusted before each test series to agree

within ±0.1 inches of a reference mercury-column barometer. The reference

barometer will be checked against the station pressure value (corrected for elevation

difference) reported by the National Weather Service.

6.1.3 Manual Sampling Quality Control Procedures

The following pretest QC checks will be conducted:

• All sampling equipment will be thoroughly checked to ensure clean and operable

components.

• Equipment will be inspected for possible damage from shipment.

• The oil manometer or Magnehelic gauge used to measure pressure across the Type S

pitot tube will be leveled and zeroed.

• The number and location of the sampling traverse points will be checked before taking

measurements.

• The temperature measurement system will be visually checked for damage and

operability by measuring the ambient temperature prior to each run.

In addition to the general QC procedures listed above, QC procedures specific to each

sampling method will also be incorporated into the sampling scheme. These methods and specific

procedures are discussed below.
HCl ICR Site-Specific Test Protocol Page: 24

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

A: Sampling Train QC checks. The following QC procedures will be emphasized:

Prior to Start of Tests

• Keep all cleaned glassware and sample train components sealed until train

assembly.

• Assemble the sampling trains in an environment free from contamination. 

• Visually inspect each sampling train for proper assembly.

• Perform pretest calculations to determine the proper sampling nozzle size.

Prior to Each Test Run

• Visually inspect the sampling nozzle.

• Visually inspect the Type S pitot tube.

• Leak check each leg of the Type S pitot tube.

• Leak check the entire sampling train.

During Each Test Run

• Readings of temperature and differential pressure will be taken at each

traverse point.

• All sampling data and calculations will be recorded on preformatted data

sheets.

• All sampling data forms will be reviewed for completeness and accuracy.

• Any unusual occurrences will be noted during each run on the appropriate data

form.

• The project supervisor will review sampling data sheets daily during testing.

• Properly maintain the roll and pitch axis of the Type S pitot tube and the

sampling nozzle.

• Leak check the train before and after any move from one sampling port to

another during a run (at DEECO’s option) or if a filter change takes place.

• Maintain the probe, filter, and impingers at the proper temperatures.

• Maintain ice in the ice bath at all times.

• Make proper readings of the dry gas meter, delta P and delta H, temperature,

and pump vacuum during sampling at each traverse point.

• Maintain isokinetic sampling within ± 10% of 100%.

After Each Test Run

• Visually inspect the sampling nozzle.

• Visually inspect the Type S pitot tube.

• Leak check each leg of the Type S pitot tube.

• Leak check the entire sampling train.

B: QC for Volumetric air flow rate determinations
HCl ICR Site-Specific Test Protocol Page: 25

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

Flue Gas Velocity. Data required to determine the flue gas velocity will be collected

using the methodology specified in EPA Method 2. Quality control procedures are

as follows.

• Visually inspect the Type S pitot tube before and after sampling.

• Leak check both legs of the pitot tube before and after sampling.

• Check the number and location of the sampling traverse points before taking

measurements.

Flue Gas Molecular Weight. Samples to be used for determination of flue gas

molecular weight will be collected using the continuous sampling technique specified

in EPA Method 3A. Quality control will focus on the following procedures:

• The sample acquisition system will be leak checked before operation.

• A constant sampling rate will be used in withdrawing a sample.

• The sampling port will be properly sealed to prevent air in-leakage.

Moisture Content. The moisture content of the gas stream will be determined using

the technique specified in EPA Method 4. The following QC checks will be

performed:

• The sampling train will be leak checked before and after each run.

• Ice will be maintained in the ice bath throughout each run.
HCl ICR Site-Specific Test Protocol Page: 26

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

7.0 REPORTING AND DATA REDUCTION REQUIREMENTS

7.1 Report Format

TABLE OF CONTENTS

1.0 Introduction 

1.1 Summary of Test Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

1.2 Key Personnel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.0 Source and Sampling Location Descriptions

2.1 Process Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.2 Control Equipment Description . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

2.3 Flue Gas and Process Sampling Locations . . . . . . . . . . . . . . . . . . . . . . . . X

3.0 Summary and Discussion of Results

3.1 Objectives and Test Matrix . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

3.2 Field Test Changes and Problems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

3.3 Summary of Results . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

4.0 Sampling and Analytical Procedures 

4.1 Emission Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

4.2 Process Test Methods . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

5.0 QA/QC Activities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X

APPENDICES

A - Results and Calculations

B - Raw Field Data

C - CEM Results

D - FTIR Results

E - Equipment Calibration Data Sheets and Calibration Certificates of Analysis

F - List of Participants
HCl ICR Site-Specific Test Protocol Page: 27

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

7.2 Data Reduction and Summary

An example data summary table is shown as Table 7.1.

TABLE 7.1 EXAMPLE DATA SUMMARY TABLE FOR HYDROGEN CHLORIDE

EMISSION TEST RESULTS, HOLCIM (US) SAINT GENEVIEVE FACILITY,

BOTH RAW MILLS OFF CONDITION; FEBRUARY 15, 2010 

Test Parameter Run X Run X Run X Average

Time xx:xx-xx:xx xx:xx-xx:xx xx:xx-xx:xx ----

Stack Gas Temperature (EF) xxx xxx xxx xxx 

Stack Gas Moisture x.x% x.x% x.x% x.x%

Volumetric Flowrate

 actual cfm

 dry standard cfm

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

xxx,xxx

Oxygen Content x.x% x.x% x.x% x.x%

Hydrogen Chloride Emissions

 Concentration, ppmby volume, wet basis

 Concentration, ppmby volume, dry basis

 Concentration, ppm at 7% oxygen

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx

x.xx
HCl ICR Site-Specific Test Protocol Page: 28

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

8.0 PLANT ENTRY AND SAFETY

8.1 Safety Responsibilities

The DEECO Safety Officer (Dr. Scott Steinsberger) is responsible for ensuring compliance

with plant entry, health, and safety requirements.

The Holcim Ste. Genvieve Plant Contact (James Lunan) has the authority to impose or waive

facility restrictions.

The DEECO Test Director (Dr. Scott Steinsberger) has authority to negotiate with facility

person any deviations from the facility restrictions.

8.2 Safety Program

The DEECO Health and Safety Program is attched as Appendix A.

8.3 Safety Requirements

All test personnel will adhere to the following standard safety and precautionary measures

as follows:

C Confine selves to test area only.

C Wear hard hats at all times on-site, except inside sample recovery trailers

and mobile CEM laboratory.

C Wear protective shoes or boots in test area.

C Wear protective glasses or goggles at the test sites, and other areas as

designated.

C Have readily available first aid equipment and fire extinguishers.

Before or on the first day on-site, the Test Director will fill out the Holcim

Contractor Job Safety Plan and the Pre-Shift Hazard Assessment form and provide

copies to be posted at each test site.
HCl ICR Site-Specific Test Protocol Page: 29

Holcim (US) Inc. Revision No: 0

Bloomsdale, Missouri Date: February 10, 2010

9.0 PERSONNEL RESPONSIBILITIES AND TEST SCHEDULE 

9.1 Test Site Organization

The key tasks and task leaders are:

C Management: William G. DeWeeS

C Test Preparation/Site Restoration: Scott C. Steinsberger

C Modifications to Facility/Services: James Lunan

C Sampling Site Accessibility: James Lunan

C Sample Recovery: Marc Hamilton

C Daily Sampling Schedule: Scott C. Steinsberger

9.2 Test Preparations

No special sampling and analytical equipment is needed. No modifications to the facility are

needed. Suitable safe access to the sampling location currently exists. Holcim will provide the

necessary electrical power. Sample recovery of the Method 4 trains will be conducted in a mobile

recovery laboratory already on-site.

9.3 Test Personnel Responsibilities and Detailed Schedule

DEECO personnel will arrive at the plant about 1.5 hours before the start of the first test run

on each of the two days scheduled for sampling. Pre-test activities on these days will include:

C Meet with the plant contact to review the daily test objectives.

C Prepare and set-up (including leak checks) the manual method trains at all test locations.

C Calibrate instrumental analyzers and verify that the data acquisition systems are

functioning properly.

C Verify communication links between team members/leaders/plant personnel.
Appendix A

DEECO Health and Safety Plan
DEECO Inc.

3404 Lake Woodard Road

Raleigh, NC 27604

(919) 250-0285 (ph); (919) 250-1835 (Fax) www.stacksampling.com

DEECO

HEALTH AND SAFETY PLAN

January 2010
DEECO

Health and Safety Plan

Section Page

1.0 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.1 Responsibilities . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1

1.2 Employee Conduct . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

1.3 Pre-Work Safety Considerations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4

1.4 Employee Safety Education, Training, and Evaluation . . . . . . . . . . . . . . . . . . . . . 4

2.0 General Safety Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.1 First Aid for Accidents and Injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7

2.2 Audit/Inspection Procedures . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

2.3 Bloodborne Pathogens . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.4 Aerial Devices (Man Lifts) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9

2.5 Confined Space Entry . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.6 Documented Safety Meetings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11

2.8 Electrical - GFCI or Grounding Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12

2.9 Equipment Inspection/Maintenance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.10 Excavation/Trenching/Shoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

2.11 Floor/Wall Openings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

2.12 Hearing Conservation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16

2.13 Housekeeping . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

2.14 Manual Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.15 Mechanical Lifting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.16 Mechanical and Electrical Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 19

2.17 New Employee Orientation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.18 Power and Hand Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.19 Process Safety Management . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

2.20 Scaffolding . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

2.21 Stairways and Ladders . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

2.22 Travel Safety . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.23 Thermal Stress . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

2.24 Welding and Cutting . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

2.26 Lockout/Tagout (LOTO) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

2.27 Fall Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27

2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen

Monitors . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 38

2.29 Emergency Response/Evacuation Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 41

2.30 Compressed Air Systems . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

2.31 Concrete Construction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

2.32 Powder-Actuated Tools . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42
Section Page

3.0 Chemical Safety Guidelines . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 43

3.1 General Characteristics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45

3.2 Acids . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.3 Bases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 47

3.4 Compressed Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 48

3.5 Cryogenic Materials . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 50

3.6 Flammable Liquids and Gases . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 51

3.7 Organic Solvents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 52

3.8 Oxidizing Agents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

3.9 Asbestos Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 53

3.10 Benzene Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

3.11 Hydrogen Sulfide Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54

3.12 Lead Awareness . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 56

4.0 Hazard Communication Requirements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 57

4.1 Material Safety Data Sheets . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 59

4.2 Chemical Labelling . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 60

4.3 Employee Exposure Monitoring . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

4.4 Employee Medical Surveillance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

4.5 Employee Access to Records . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 61

5.0 Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

5.1 Respiratory Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 63

5.2 Gloves . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

5.3 Protective Eyewear . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 66

5.4 Protective Clothing . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 67

5.5 OSHA Levels of Protection . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 68

5.5 Training for the Use Personal Protective Equipment . . . . . . . . . . . . . . . . . . . . . . 70
DEECO Health and Safety Plan Page 1 January 2010

1.0 Introduction

DEECO, Inc. (DEECO) is committed to the health and safety of its employees. In order to ensure

that all tasks are performed safely, this Health and Safety Plan (HSP) has been prepared. The

procedures detailed in this HSP outline individual responsibilities, specific operating procedures,

training requirements, and specific information on potential safety and health hazards.

The hazards faced by DEECO field personnel are varied, and specific controls of many hazards are

the responsibility of the client. This HSP will enable employees to recognize potential hazards so

that the client may take actions to correct the condition before the work is performed. This HSP also

identifies DEECO activities which may pose significant health and safety risks. 

1.1 Responsibilities

This section details the responsibilities for employees and management in the implementation of the

HSP.

President

The President of DEECO has overall responsibility for compliance with all applicable federal and

state regulations and the provisions of this HSP. Periodic meetings with managers and employees

should be conducted to discuss:

# The importance of health and safety.

# Changes in regulations regarding health and safety.

# Recent employee monitoring results.

# Any recent employee accidents/injuries and possible preventive measures to avoid

a recurrence.

In addition to the above responsibilities, the President is responsible for authorizing any deviations

from the HSP.

Managers

Project managers and field team leaders are responsible for the health and safety of all persons

assigned to the specific project. Project managers and field team leaders must ensure that:

# Employees are properly trained to perform all tasks in a safe manner.

# Proper personal protective equipment are available and in good working condition.

# Persons using personal protective equipment have been instructed on their use.

# Emergency equipment is available and in good working condition.

# Employees are informed of any exposure monitoring performed in their work area

that may be representative of their chemical exposure.

# All safety considerations have been discussed with the client prior to mobilization.

# All aspects of the projects have been discussed and are understood with the team

leader and team members.

# All appropriate safety equipment is available and in good working condition prior to

mobilization.

# All records (employee training, respirator fit-testing, etc.) are present for all team
DEECO Health and Safety Plan Page 2 January 2010

members.

# Copies of MSDSs for all chemicals used by DEECO are available for the client.

# All tasks are performed in a safe manner.

# All accidents, injuries, or spills are reported immediately.

# Any unsafe condition is reported immediately.

# They cooperate with any monitoring surveys.

DEECO Safety Officer

The DEECO Safety Officer (SO) is responsible for the review and maintenance of the Health &

Safety Plan. In addition, the SO is responsible for:

# Identifying when employee exposure monitoring is necessary.

# Writing exposure reports and reporting results to the appropriate department manager

and employees.

# Ensuring that appropriate employee training is provided.

# Investigating reported accidents with department managers.

# Ensuring that new information on health, safety, employee training, or changes in

legal requirements are conveyed to the Director of Field Services. 

1.2 Employee Conduct

Appropriate employee conduct is essential in conveying a professional image to DEECO clients.

When performing work on client premises:

# Dress professionally.

# Contact the team leader if problems with a client arises.

# Discuss disagreements with other DEECO personnel in private, not in front of the

client.

# Do not discuss DEECO company policies or practices with clients (e.g. management,

compensation. etc.)

# Direct all questions regarding sampling or project activities to the team leader.

# Do not convey DEECO in a negative manner to clients. Any disagreements with

company practices should be discussed directly with your manager.

# Do not volunteer data to client employees.

# Release data only to the designated client contact.

# Do not promise a date for the final report. Have the client contact the project

manager or coordinator for a final report date.

# Remain busy while on the client's premises.

# Remain within designated areas of plant site.

# Notify team leader when leaving area.

# Notify client when leaving site for lunch or the end of the day.

# Be on time for client meetings. If problems arise, call the client immediately if the

scheduled time cannot be kept.

# Follow all rules and regulations of the client while on the plant site.

# If approached by the news media, do not offer any information. Refer all questions

to the client.
DEECO Health and Safety Plan Page 3 January 2010

Drugs and Alcohol Use

It is DEECO's desire to provide a drug-free, healthful, and safe workplace. To promote this goal,

employees are required to report to work in appropriate mental and physical condition to perform

their jobs in a satisfactory manner.

While on DEECO premises and while conducting business-related activities off DEECO premises,

no employee may use, possess, distribute, sell, or be under the influence of alcohol or engage in the

unlawful manufacture, distribution, dispensation, possession, or use of illegal drugs. Violations of

this policy may lead to disciplinary action, up to and including immediate termination of

employment, and/or required participation in a substance abuse rehabilitation or treatment program.

Such violations may also have legal consequences.

The legal use of prescribed drugs is permitted on the job only if it does not impair an employee's

ability to perform the essential functions of the job effectively and in a safe manner that does not

endanger other individuals in the workplace.

To inform employees about important provisions of this policy, DEECO has established a drug-free

awareness program. The program provides information on the dangers and effects of substance

abuse in the workplace, resources available to employees, and consequences for violations of this

policy.

Employees with questions or concerns about substance dependency or abuse are encouraged to

discuss these matters with their supervisor or the Personnel Director to receive assistance or referrals

to appropriate resources in the community.

Employees with drug or alcohol problems that have not resulted in, and are not the immediate

subject of, disciplinary action may request approval to take unpaid time off to participate in a

rehabilitation or treatment program through DEECO's health insurance benefit coverage. Leave may

be granted if the employee agrees to abstain from use of the problem substance; abides by all

DEECO policies, rules, and prohibitions relating to conduct in the workplace; and if granting the

leave will not cause DEECO any undue hardship.

Under the Drug-Free Workplace Act, an employee who performs work for a government contract

or grant must notify DEECO of a criminal conviction for drug-related activity occurring in the

workplace. The report must be made within five days of the conviction.

Employees with questions on this policy or issues related to drug or alcohol use in the workplace

should raise their concerns with their supervisor or the Personnel Director without fear of reprisal.

Abusive Language

Abusive or vulgar language, ethnic or sexual slurs and insults will not be tolerated on client or

DEECO premises. Use of such language is not only offensive, but may be seen as illegal

harassment. Inappropriate language or insults can result in immediate, appropriate action upon the

employee by DEECO. If problems with employee use of such language occurs, notify your manager.
DEECO Health and Safety Plan Page 4 January 2010

1.3 Pre-Work Safety Considerations

The Project Coordinator or Manager should determine through a site visit, or through extensive

conversations with the client, if any unusual safety hazards exist at the work site. Additional

equipment, if needed, should be determined by the Project Coordinator/Manager and the DEECO

S.O.

1.4 Employee Safety Education, Training, and Evaluation

All DEECO personnel shall initially receive the equivalent of the OSHA 40-hour Training for

Hazardous Waste Operators. The 8-hour Refresher Training shall be completed annually by all

personnel.

Additional training and education may be required for specific job responsibilities. The training

requirements for additional education shall be set by the President.

Employee Safety Evaluation Program

An annual evaluation of each employee’s safety performance will be conducted.

Evaluating an employee’s safety performance involves measuring the level at which employees are

achieving both their own personal safety goals and the company’s expected safety performance

standards. Integrating health and safety into a performance appraisal system provides management

with a unique opportunity to tie the employee’s accountabilities and achievements to the company’s

objectives and strategic plans. 

The goals of the Employee Safety Evaluation Program are;

1. Communicating information to employees on how well they are meeting the health and

safety performance expectations of their jobs;

2. Identifying areas for coaching to help employees improve their health and safety performance

and develop safe work practices;

3. Providing opportunities to further communicate the organization’s health and safety

performance expectations;

4. Supporting the organizational succession plan;

5. Providing feedback to the organization about its recruitment and selection process as well

as its integrated health and safety training/development program; 

6. Providing feedback about the employee’s perceptions of the company’s health and safety

performance and standards. 

For employees, meeting the health and safety expectations of a job requires them to:

1. Report hazards or hazardous conditions to their supervisor;
DEECO Health and Safety Plan Page 5 January 2010

2. Work in a safe manner at all times by using appropriate protective gear and controls on

equipment;

3. Follow company policies and procedures;

4. Wear personal protective equipment as instructed;

5. Participate in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)

For supervisors, meeting the health and safety expectations of a job requires the ability to: 

1. Coach employees on safe work practices;

2. Enforce company policies and procedures;

3. Act as a positive role model for staff with respect to safe work practices;

4. Support any staff who are members of the joint health and safety committee;

5. Be aware of their legal requirements under the Occupational Health and Safety Act;

6. Review new jobs/tasks/processes/equipment for safety concerns;

7. Follow-up on reported concerns in a timely fashion;

8. Encourage employee input into safety-related concerns and solution-finding processes; and

9. Discipline staff when required for failure to follow safety procedures.

The Employee Safety Evaluation Program will quantify the health and safety areas being monitored

and provide qualitative feedback on employee health and safety performance.

The Employee Safety Evaluation Program will evaluate a employee’s performance on the following;

1. Reporting hazards or hazardous conditions to their supervisor;

2. Working in a safe manner at all times by using appropriate protective gear and controls on

equipment;

3. Following company policies and procedures;

4. Wearing personal protective equipment as instructed;

5. Participating in health and safety initiatives (e.g. ergonomic assessment, hygiene testing etc.)

The Employee Safety Evaluation Program will evaluate a supervisor’s performance on the following;
DEECO Health and Safety Plan Page 6 January 2010

1. Effectiveness in managing health and safety issues in their department or area of

responsibility; and

2. Establishing specific criteria for minimum health and safety standards.
DEECO Health and Safety Plan Page 7 January 2010

2.0 General Safety Requirements

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

safety procedures, field personnel are to follow the procedures which are more stringent. In all cases,

all OSHA, MSHA and/or EPA requirements shall be met.

2.1 First Aid for Accidents and Injuries

In the absence of an infirmary, clinic, hospital, or physician, that is reasonably accessible in terms

of time and distance to the worksite, which is available for the treatment of injured employees, a

person who has a valid certificate in first-aid training from the U.S. Bureau of Mines, the American

Red Cross, or equivalent training that can be verified by documentary evidence, shall be available

at the worksite to render first aid. 

First aid supplies shall be easily accessible when required. The contents of the first aid kit shall be

placed in a weatherproof container with individual sealed packages for each type of item, and shall

be checked by the employer before being sent out on each job and at least weekly on each job to

ensure that the expended items are replaced.

Proper equipment for prompt transportation of the injured person to a physician or hospital, or a

communication system for contacting necessary ambulance service, shall be provided.

In areas where 911 is not available, the telephone numbers of the physicians, hospitals, or

ambulances shall be conspicuously posted.

Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable

facilities for quick drenching or flushing of the eyes and body (e.g. safety showers and emergency

eyewash systems) shall be provided within the work area for immediate emergency use. The

location of these facilities for quick drenching or flushing of the eyes and body shall be identified

and all employees in the affected area will be shown the location of these facilities.

The reporting of any work-related accident, illness, or injury is required by Worker's Compensation

regulations. North Carolina law requires that a manager's report on an accident or injury be filed

within 10 days after the incident.

The reporting of incidents will enable employees and management to determine what possible

corrective actions can be taken to avoid a recurrence of the incident.

Responsibilities

Project managers or coordinators must ensure that:

# Immediate care is obtained for all accidents or injuries.

# All employee accidents or injuries are recorded on the DEECO Accident Report form

by the employee.

# Copies of the Accident Report form are sent to the Personnel Director and the

DEECO S.O.
DEECO Health and Safety Plan Page 8 January 2010

# Accident reports are reviewed with the employee and possible preventive measures

are noted and implemented if required.

# Any equipment involved in an incident is removed from service until repaired or

replaced.

The Personnel Director must ensure that:

# Necessary North Carolina forms are completed, distributed, and maintained for any

occupational injury or accident.

# The OSHA Form 300 is updated and posted on the bulletin board in the Break Room.

Employees must ensure that:

# All accidents or injuries are reported immediately to the Department Manager,

Project Manager, or Project Coordinator.

# All details of the accident or injury are recorded on the DEECO Accident Report

form.

2.2 Audit/Inspection Procedures

Safety audits and inspections of all work areas will be conducted periodically by the Safety Officer

or a representative thereof. Procedures for conducting an inspection of a job site will be as follows.

The following items, while not inclusive, are indicators of some of the areas of concern for good job

site safety covered in a routine inspection or audit.

Item Acceptable Not Acceptable NA

Employee Safety Training ( ) ( ) ( )

Safety Manual On site ( ) ( ) ( )

Assigned Responsibilities ( ) ( ) ( )

Confined Space Entry ( ) ( ) ( )

Fire Protection ( ) ( ) ( )

Electrical - GFCI or Grounding Program ( ) ( ) ( )

Equipment Inspection/Maintenance ( ) ( ) ( )

Excavation/Trenching/Shoring ( ) ( ) ( )

Floor/Wall openings ( ) ( ) ( )

Hearing Conservation ( ) ( ) ( )

Housekeeping ( ) ( ) ( )

Mechanical Lifting ( ) ( ) ( )

Mechanical and Electrical Safety ( ) ( ) ( )

Power Tools ( ) ( ) ( )

Scaffolding ( ) ( ) ( )

Stairways and Ladders ( ) ( ) ( )

Travel Safety Followed ( ) ( ) ( )

Thermal Stress ( ) ( ) ( )

Chemical Safety Guidelines Met ( ) ( ) ( )

Hazard Communication Requirements Met ( ) ( ) ( )

Material Safety Data Sheets On site ( ) ( ) ( )

Chemical Labelling Clear and correct ( ) ( ) ( )

Personal Protective Equipment ( ) ( ) ( )
DEECO Health and Safety Plan Page 9 January 2010

Respiratory Protection ( ) ( ) ( )

Gloves ( ) ( ) ( )

Protective Eyewear ( ) ( ) ( )

Protective Clothing ( ) ( ) ( )

Fall Protection ( ) ( ) ( )

2.3 Bloodborne Pathogens

In the normal course of work, it is not reasonably anticipated that DEECO employees will encounter

occupational exposure of the skin, eye, mucous membrane, or parenteral contact with blood or other

potentially infectious materials. Consequently, DEECO is not required to have a written Exposure

Control Plan.

However, in the case of an accident, all contact with blood or blood products should be avoided to

prevent the risk of exposure to bloodborne pathogens, . Cuts, scrapes, and abrasions should be

reported to the safety officer or appointed representative and proper health care should be provided

by trained personnel. Rubber gloves should be worn at all times when treating injuries causing risk

to bloodborne pathogens. 

Rubber gloves, protective resuscitation masks, and other first aid items are contained in the field first

aid kit which is to be present on each project.

2.4 Aerial Devices (Man Lifts)

On occasions, DEECO employees may be required to use aerial devices (man lifts) to access

sampling locations. The following are examples of aerial devices;

1. An aerial device is any vehicle-mounted device, telescoping or articulating, or both, which

is used to position personnel;

2. An aerial ladder is an aerial device consisting of a single- or multiple-section extensible

ladder;

3. An articulating boom platform is an aerial device with two or more hinged boom sections.;

4. An extensible boom platform is an aerial device (except ladders) with a telescopic or

extensible boom. Telescopic derricks with personnel platform attachments shall be

considered to be extensible boom platforms when used with a personnel platform;

5. An insulated aerial device is an aerial device designed for work on energized lines and

apparatus;

5. A mobile unit is a combination of an aerial device, its vehicle, and related equipment;

6. A platform is any personnel-carrying device (basket or bucket) which is a component of an

aerial device;

7. A vehicle is any carrier that is not manually propelled; and
DEECO Health and Safety Plan Page 10 January 2010

8. A vertical tower is an aerial device designed to elevate a platform in a substantially vertical

axis.

Specifc Requirements for Aerial Lifts

Only trained persons shall operate an aerial lift.

For ladder trucks and tower trucks, before the truck is moved for highway travel, aerial ladders will

be secured in the lower traveling position by the locking device above the truck cab, and the

manually operated device at the base of the ladder, or by other equally effective means (e.g., cradles

which prevent rotation of the ladder in combination with positive acting linear actuators).

For extensible and articulating boom platforms, the lift controls shall be tested each day prior to use

to determine that such controls are in safe working condition.

Belting off to an adjacent pole, structure, or equipment while working from an aerial lift shall not

be permitted.

Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge

of the basket or use planks, ladders, or other devices for a work position.

A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial

lift.

Boom and basket load limits specified by the manufacturer shall not be exceeded.

The brakes shall be set and outriggers, when used, shall be positioned on pads or a solid surface.

Wheel chocks shall be installed before using an aerial lift on an incline.

An aerial lift truck may not be moved when the boom is elevated in a working position with men in

the basket, except for equipment which is specifically designed for this type of operation in

accordance with the provisions of OSHA 1910.67, paragraphs (b)(1) and (b)(2).

Articulating boom and extensible boom platforms, primarily designed as personnel carriers, shall

have both platform (upper) and lower controls. Upper controls shall be in or beside the platform

within easy reach of the operator. Lower controls shall provide for overriding the upper controls.

Controls shall be plainly marked as to their function. Lower level controls shall not be operated

unless permission has been obtained from the employee in the lift, except in case of emergency.

Climbers shall not be worn while performing work from an aerial lift.

The insulated portion of an aerial lift shall not be altered in any manner that might reduce its

insulating value.

Before moving an aerial lift for travel, the boom(s) shall be inspected to see that it is properly cradled

and outriggers are in stowed position, except as provided in OSHA 1910.67, paragraph (c)(2)(viii).
DEECO Health and Safety Plan Page 11 January 2010

2.5 Confined Space Entry

A Confined Space in an enclosure having limited access and egress. Examples of confined spaces

include, but are not limited to:

# Storage tanks, tank cars, process vessels, bins, silos, boilers, and other tank-like

compartments usually with only a manhole for entry.

# Open-topped spaces of more than 4 feet in depth, such as pits, vaults and vessels, not

subject to good natural ventilation.

# Septic tanks, sewers, underground utility tunnels, pipelines, and similar structures.

Confined spaces may contain atmospheres that are hazardous to life and health because of the

presence of flammable, explosive, or toxic contaminants or because of either a deficiency or excess

of oxygen. It is DEECO policy not to permit employees to enter a confined space. In the event that

confined space entry is necessary as part of a project, the client is to provide DEECO personnel with

training, life-support equipment, and emergency/rescue personnel during any confined space work.

2.6 Documented Safety Meetings

Safety Meetings will be held on the first day of a project, on-site. A review of safety conditions will

be made by the project manager/field team leader at the end of each day's work. Any unusual or

notable health or safety concerns will be noted in the field log, and discussed with all field team

members. All field safety meetings will be documented in the field log book, and a copy of the

appropriate pages will be included in the final written report to the client.

The President shall ensure that meetings are held periodically to address safety violations,

procedures, and/or updates. The dates, attendees, and topics of these meetings will be documented

and placed in the Safety Meetings file.

2.7 Fire Protection

Every employee should be aware of the combustible characteristics of the chemicals and materials

they use or may come in contact with. This information can be found on the chemical's Material

Safety Data Sheet (MSDS), or labels on the material container.

When performing work on a client's site, the Project Manager or Coordinator must:

# Be able to clearly identify all regular and emergency exits in the building or work

area.

# Receive a site evacuation route from the client.

# Receive emergency notification procedures from the client (e.g. number to call in

case of fire, explosion, etc.).

# Ensure all team members are aware of the above information.

Care should be taken when storing or using chemicals or hazardous materials in DEECO vehicles

or mobile laboratories. All vehicles and mobile laboratories are equipped with fire extinguisher.

If a fire should occur:

# Aim fire extinguisher at the base of the fire.

# Never allow the fire to come between you and an exit.

# Never use water on electrical or burning liquid fires.

If the fire is too large to be contained with one fire extinguisher:
DEECO Health and Safety Plan Page 12 January 2010

# Immediately notify the site emergency contact. Report location of fire, material

burning, and if any injuries are involved.

# Evacuate the area.

Fire Extinguisher Classes

Class A - for use on ordinary combustible materials such as paper, wood, etc.

Class B - for use on flammable and combustible liquids, greases, paints, etc.

Class C - for use on electrical fires.

Class D - for use on combustible metals.

All fire extinguishers located in the DEECO vehicles and mobile laboratories are rated for Class A,

B, and C fires.

2.8 Electrical - GFCI or Grounding Program

It is the policy of DEECO to establish and implement an assured equipment grounding conductor

program on work sites covering all cord sets, receptacles which are not a part of the permanent

wiring of the building or structure, and equipment connected by cord and plug which are available

for use or used by employees. This policy shall apply to all work sites not equipped with ground

fault circuit interrupters in accordance with OSHA standard 1926.400 (h).

The project manager/field team leader shall implement the assured equipment grounding conductor

program where existing and predictable hazards are identifyedi the surrounding area or working

conditions which are unsanitary, hazardous or dangerous to employees, and who is authorized to take

prompt corrective measures to eliminate them.

The project manager/field team leader shall be responsible and accountable for the following:

Each cord set, attachment cap, plug and receptacle of cord set and any equipment connected by cord

and plug, except cord sets and receptacles which are fixed and not exposed to damage, shall be

visually inspected before each day's use for external defects, such as deformed or missing pins, or

insulation damage, and for indication of possible internal damage. Equipment found damaged or

defective may not be used until repaired.

The project manager/field team leader is responsible for tests on all cord sets, receptacles which are

not a part of the permanent wiring of the building or structure, and cord and plug connected

equipment repaired to be grounded. Tests shall be documented on the log for assured equipment

grounding conductor program and shall be on the job site for inspection by OSHA officials and any

affected employee. Equipment that does not meet prescribed test shall not be put into service. The

following tests shall be performed:

1. All equipment grounding conductors shall be tested for continuity and shall be electrically

continuous.
DEECO Health and Safety Plan Page 13 January 2010

2. Each receptacle and attachment cap or plug shall be tested for correct attachment of the

equipment grounding conductor. The equipment grounding shall be connected to its

terminal..

In accordance with OSHA Construction Safety and health Standards 1926.21 Safety Training and

Education, project manager/field team leader shall attend such training sessions as the company may

deem necessary.

A copy of this policy shall be at the job site for inspection and copy by OSHA officials and any

affected employee. Management retains the authority to designate that certain jobs comply with

regulation 1926.400 (h) by use of ground fault circuit interrupters in lieu of the program established

above. A copy of the completed forms will be kept on each applicable job site for inspection

purposes.

Electric power operated tools and power cords shall be UL approved, double insulated or have the

third wire ground whole and in place. All 120-volt single phase, 15- and 20-ampere receptacle

outlets on construction sites, which are not a part of the permanent wiring of the building or structure

and which are in use by employees, shall have approved ground-fault circuit interrupters (GFCI) for

personnel protection.

All equipment and power cords are to be inspected prior to the field project. Any equipment or

power cord which is not in proper working order shall be tagged as "DAMAGED-DO NOT USE"

and returned to the DEECO laboratory for repair or replacement.

2.9 Equipment Inspection/Maintenance

Mechanical and electrical equipment will be periodically inspected according to the manufacturers

instructions to ensure they are in proper working order, all cords and parts are not chipped, frayed

or broken, and recommended maintenance procedures are conducted on schedule. Equipment that

does not meet safety standards will be repaired or replaced before use.

2.10 Excavation/Trenching/Shoring

DEECO personnel shall not perform excavation or trenching work, nor shall DEECO personnel be

expected to enter an excavation or trench. Should such entry be required on a project, the client must

ensure:

- Underground lines, equipment and electrical cables shall be located, identified and

de-energized prior to beginning work.

- Walls and faces of trenches and excavations, four or more feet deep, are shored,

sloped or shielded as dictated by the type of soil encountered.

- Daily inspections are conducted by a competent person for evidence of a situation

that could result in possible cave-ins, indications of failure of protective systems or

other hazardous conditions.

- Employees are not be permitted underneath loads handled by lifting or digging

equipment. Employees shall be required to stand away from any vehicle being

loaded or unloaded.
DEECO Health and Safety Plan Page 14 January 2010

- Employees are be protected from excavated or other materials and equipment that

could pose a hazard by falling or rolling in excavations.

 - Physical barriers are be placed around or over trenches and excavations. Barriers

shall be removed only when necessary to provide access to personnel or equipment.

Flashing light barricades shall be provided at night.

- A stairway, ladder, ramp or other safe means of egress is located in trench

excavations that are four feet or more in depth so as to require no more than 25 feet

of lateral travel for employees.

- Backfilling and removal of support systems are performed only after employees have

cleared the area. All excavations shall be backfilled and graded promptly.

- Trenches greater than four feet deep shall require an approved confined space entry

permit.

The client requiring DEECO personnel to enter a trench or excavation shall provide training to

DEECO personnel in accordance to client and OSHA regulations and policies.

2.11 Floor/Wall Openings

With regards to guarding floor and wall openings and holes, workers will comply with 29 CFR

1910.23 and 1926, Subpart M.

General requirements are as follows:

1. Ladderway floor openings shall be guarded by a standard railing and toe-boards or cover.

In general, the railing shall be provided on all exposed sides, except at entrances to stairways.

2. Hatchways and chute floor openings shall be guarded by one of the following:

a. Hinged covers and a standard railing with only exposed side.

b. A removable standard railing with toe-board on not more than two sides and fixed

standard railings with toe boards on all other exposed sides.

3. Temporary floor openings, into which persons can accidentally walk, shall be guarded by

either a standard railing with toe-board on all exposed sides, or a floor hole cover that is

secured against accidental displacement.

4. Wall openings, from which there is a drop of more than four feet, and the bottom of the

opening is less than three feet above the working surface, shall be guarded as follows:

a. A standard rail, if that will effectively reduce the danger of falling. If the bottom of

a wall opening is less than four inches above the working surface, a toe-board or an

enclosing screen shall also be provided.

5. Every open-sided floor or platform four feet or more above adjacent floor or ground level

shall be guarded by a standard railing or equivalent. A toe-board shall be provided wherever,

beneath the open sides, persons can pass or there is moving machinery or there is equipment

with which falling material could create a hazard.
DEECO Health and Safety Plan Page 15 January 2010

Standard Specifications

1. A standard railing shall consist of top rail, intermediate rail, toe-board and posts, and shall

have a vertical height of approximately 42 inches.

a. The intermediate rail shall be halfway between the top rail and the floor, platform

runway or ramp.

b. Posts shall be spaced not more than eight feet on corners.

c. A completed railing structure shall be capable of withstanding a load of at least 200

pounds applied in any direction at any point on the top rail, with a minimum of

deflection.

2. A standard handrail shall be of a construction similar to a standard rail except that it is

mounted on a wall or partition and does not include an intermediate rail.

a. The height to handrails shall not be more than 34 inches or less than 30 inches from

top surface to tread or ramp.

b. Handrails and railings shall be provided with a clearance of approximately three

inches between the rail and any other object.

3. Floor opening covers shall be of any material that meets the following strength requirements:

a. The cover, when located in roadways or vehicular aisles, shall be designed to carry

a truck rear axle load of at least two times the maximum intended load.

b. The floor opening cover shall be capable of supporting the maximum intended load

and so installed as to prevent accidental displacement.

4. Wall opening protection shall meet the following requirements:

a. Barriers shall be of such construction and mounting that, when in place, they are

capable of withstanding a load of at least 200 pounds applied in any direction (except

upward) with a minimum deflection.

5. During the performance of work on low pitched roofs, employees shall be protected at all

open sides and edges by the use of a motion-stopping safety system.

Barricades

1. Signs, signals and barricades shall be posted to detour passage of persons and vehicles at

locations where potential hazards exist.

a. Barricades must be 42 inches high.

b. Barricades should be kept four feet back from the edge of excavations, holes, and

platforms and six feet back from the edge of low-pitched roofs.

c. Barricades with flashing lights shall be provided at night.
DEECO Health and Safety Plan Page 16 January 2010

2. All employees engaged in built-up roofing work will undergo training so that they are able

to recognize and deal with the hazards of falling associated the working near a roof

perimeter.

2.12 Hearing Conservation

DEECO personnel may be exposed to excessive noise levels while on a client's premises. The

project manager/field team leader will ensure all high noise areas have been identified, and that each

member of the field team is aware of the location of these areas. Hearing protection is to be provided

by DEECO to field personnel at no cost. Employees will wear hearing protection as instructed and

in all areas required.

Hearing Conservation Training Program

DEECO will train each employee who is exposed to noise at or above an 8-hour time weighted

average of 85 decibels. DEECO will institute a training program and ensure employee participation

in the program.

The training program will be repeated annually for each employee included in the hearing

conservation program. Information provided in the training program will be updated to be consistent

with changes in protective equipment and work processes.

DEECO will ensure that each employee is informed of the effects of noise on hearing, the purpose

of hearing protectors, the advantages, disadvantages, and attenuation of various types, and

instructions on selection, fitting, use, and care, and the purpose of audiometric testing and an

explanation of the audiometric test procedures.

DEECO will provide annual audiometric exams for all personnel. The President is responsible for

ensuring compliance with applicable regulations (29 CFR 1910.95, "Occupational Noise Exposure",

and 1926.101, "Hearing Protection"). 

Audiometric Testing Program

DEECO will establish and maintain an audiometric testing program by making audiometric testing

available to all employees whose exposures equal or exceed an 8-hour time-weighted average of 85

decibels. The program shall be provided at no cost to employees.

Audiometric tests will be be performed by a licensed or certified audiologist, otolaryngologist, or

other physician, or by a technician who is certified by the Council of Accreditation in Occupational

Hearing Conservation, or who has satisfactorily demonstrated competence in administering

audiometric examinations, obtaining valid audiograms, and properly using, maintaining and

checking calibration and proper functioning of the audiometers being used. A technician who

operates microprocessor audiometers does not need to be certified. A technician who performs

audiometric tests must be responsible to an audiologist, otolaryngologist or physician.

All audiograms obtained pursuant to this section shall meet the requirements of OSHA 1910,

Appendix C: "Audiometric Measuring Instruments."
DEECO Health and Safety Plan Page 17 January 2010

Baseline Audiogram

Within 6 months of an employee's first exposure at or above the action level, DEECO will establish

a valid baseline audiogram against which subsequent audiograms can be compared.

Where baseline audiograms are obtained more than 6 months after the employee's first exposure at

or above the action level, employees shall wear hearing protectors for any period exceeding six

months after first exposure until the baseline audiogram is obtained.

Testing to establish a baseline audiogram shall be preceded by at least 14 hours without exposure

to workplace noise. Hearing protectors may be used as a substitute for the requirement that baseline

audiograms be preceded by 14 hours without exposure to workplace noise. DEECO will notify

employees of the need to avoid high levels of non-occupational noise exposure during the 14-hour

period immediately preceding the audiometric examination.

Annual Audiogram

At least annually after obtaining the baseline audiogram, DEECO will obtain a new audiogram for

each employee exposed at or above an 8-hour time-weighted average of 85 decibels.

Evaluation of Audiogram

Each employee's annual audiogram will be compared to that employee's baseline audiogram to

determine if the audiogram is valid and if a standard threshold shift (as defined in OSHA

1910.95(g)(10)) has occurred. This comparison may be done by a technician.

If the annual audiogram shows that an employee has suffered a standard threshold shift, DEECO will

obtain a retest within 30 days and consider the results of the retest as the annual audiogram.

An audiologist, an otolaryngologist, or a physician will review problem audiograms and will

determine whether there is a need for further evaluation. DEECO will provide to the person

performing this evaluation, a copy of the requirements for hearing conservation as set forth in OSHA

1910.95 paragraphs (c) through (n), the baseline audiogram and most recent audiogram of the

employee to be evaluated, measurements of background sound pressure levels in the audiometric test

room as required in OSHA 1910Appendix D: Audiometric Test Rooms, and records of audiometer

calibrations required by OSHA 1910 paragraph (h)(5).

Follow-up Procedures

If a comparison of the annual audiogram to the baseline audiogram indicates a standard threshold

shift, the employee will be informed of this fact in writing, within 21 days of the determination.

Unless a physician determines that the standard threshold shift is not work related or aggravated by

occupational noise exposure, DEECO will ensure that the employees not using hearing protectors

will be fitted with hearing protectors, trained in their use and care, and required to use them.

Employees already using hearing protectors shall be refitted and retrained in the use of hearing

protectors and provided with hearing protectors offering greater attenuation if necessary.
DEECO Health and Safety Plan Page 18 January 2010

The employee will be referred for a clinical audiological evaluation or an otological examination,

as appropriate, if additional testing is necessary or if DEECO suspects that a medical pathology of

the ear is caused or aggravated by the wearing of hearing protectors.

The employee will be informed of the need for an otological examination if a medical pathology of

the ear that is unrelated to the use of hearing protectors is suspected.

If subsequent audiometric testing of an employee whose exposure to noise is less than an 8-hour

TWA of 90 decibels indicates that a standard threshold shift is not persistent, DEECO will inform

the employee of the new audiometric interpretation and mMay discontinue the required use of

hearing protectors for that employee.

Revised Baseline

An annual audiogram may be substituted for the baseline audiogram when, in the judgment of the

audiologist, otolaryngologist or physician who is evaluating the audiogram, that the standard

threshold shift revealed by the audiogram is persistent or the hearing threshold shown in the annual

audiogram indicates significant improvement over the baseline audiogram.

2.13 Housekeeping

Employees shall maintain a high standard of housekeeping on the job at all times as an integral part

of the work The purpose of this requirement is to ensure the safety of all personnel entering the lob

location and to maintain a condition of housekeeping that is consistent with the desired appearance

of a DEECO job location.

Project managers/field team leaders shall clean up work areas daily, store all equipment and

construction materials in an orderly manner in storage areas. Barricades shall be used for temporary

storage of equipment and construction materials. All scrap construction materials and waste shall

be picked up and disposed of at least daily. All location procedures for waste disposal shall be

followed. Form wood and other lumber shall be neatly stored when not in use. All nails shall be

removed or bent over to prevent puncture wounds.

All stairways, walkways, ladder cages and scaffolds shall be kept clear of all cords, cables, hosed,

materials and anything else that might hinder personnel access. Cords, cables and hosed at stairways,

walkways and scaffolds will be supported at least seven feet overhead or laid flat outside of

walkways.

All spills of oil, solvents, chemicals and any regulated liquids shall be reported to the site

representative immediately and shall be properly cleaned up and disposed of. Dumping of these

materials in floor drains, sanitary sewers, storm sewers. drainage ditches, or other open ground is

forbidden.

Employees shall be responsible for keeping all location roads free from all debris resulting from their

performance of the work. Storage of combustible and flammable materials shall not be located under

overhead pipelines and utilities. Loose materials on roofs or other overhead structures shall be

removed or secured to prevent being blown or bumped off. Accumulation of materials that may
DEECO Health and Safety Plan Page 19 January 2010

create a fire hazard shall not be permitted. Storage of materials shall be at least eight feet from the

center of railroad tracks.

Project managers/field team leaders shall perform a housekeeping review of the work site at the end

of each day. All concerns noted will be corrected prior to the field team leaving the site.

2.14 Manual Lifting

When lifting heavy objects, an improper lifting technique may result in a serious injury. When

lifting objects, ensure that you:

# Know your limitation. Enlist help before lifting objects that are beyond your

strength.

# Have cleared a path to carry the object, before lifting the object.

# Lift with your legs, keeping your back straight.

# Have a firm grip and a sure footing before lifting the object.

# Lift objects gradually. Avoid jerking motions and awkward positions.

# Avoid twisting your body when carrying the object. Turn your entire body with the

object.

2.15 Mechanical Lifting

Mechanical lifting aids, such as hoists, trucks, dollies, and jacks are to be used to assist Field

personnel in handling heavy objects. Field personnel must ensure that:

# The rated capacity of the mechanical device is not exceeded.

# When lifting objects to a higher work location, the area below the lifted object is kept

clear by restricting access using ropes, barricades, or other barriers.

# Loads are not left suspended in the air. Raise the load only when it can be unloaded

at its destination.

# Attempts are not made to catch or grab falling objects.

2.16 Mechanical and Electrical Safety

Analytical Equipment

The use and repair of analytical equipment can present unusual electrical and mechanical hazards.

Before performing work on any piece of equipment:

# Ensure that power has been disconnected from the unit.

# Ensure that any reserve power (capacitors, batteries) are de-energized before working

on unit.

# Do not remove any piece of equipment labelled "Trained Service Personnel Only".

Call the appropriate service organization for repair of the unit.

Additional mechanical and electrical hazards may exist. Employees must be aware of all hazards

before performing any repair work. Employees should consult the client's representative before

connecting transformers or other electrical lines to power supplies. See Lockout/Tagout procedures

in the Supplement of this manual.
DEECO Health and Safety Plan Page 20 January 2010

2.17 New Employee Orientation

All new employees will undergo initial safety training which includes assigned responsibilities, first

aid procedures (including bloodborne pathogens procedures), accident response and reporting

procedures, emergency action plan and spill procedures, fire protection, general safety rules, and

housekeeping. Subsequent safety training will be provided based on job description.

2.18 Power and Hand Tools

Improper use of power and hand tools can lead to serious injuries. Field personnel should be familiar

with the tools used and their operating manuals. Field personnel should ensure that:

# Tools are used for the propose for which they were designed.

# Power tools must be either grounded or double-insulated.

# Defective or damaged tools must be labelled and stored such that other employees

will not mistakenly use the tool.

# Safety glasses with side shields or goggles must be worn when using power tools that

may produce projectiles.

2.19 Process Safety Management

Many client locations will be required to provide DEECO (the contract employee) with process

safety management (PSM) information. The processes that require PSMs involves a flammable

liquid or gas (as defined in OSHA 1926.59(c)) on site in one location, in a quantity of 10,000 pounds

(4535.9 kg) or more except for hydrocarbon fuels used solely for workplace consumption as a fuel

(e.g., propane used for comfort heating, gasoline for vehicle refueling), if such fuels are not a part

of a process containing another highly hazardous chemical covered by this standard and flammable

liquids stored in atmospheric tanks or transferred which are kept below their normal boiling point

without benefit of chilling or refrigeration. PSM describes the procedures for preventing or

minimizing the consequences of catastrophic releases of toxic, reactive, flammable, or explosive

chemicals. These releases may result in toxic, fire or explosion hazards

The DEECO project manager/field team leader shall ensure that all DEECO employees understand

and follow these procedures.

Management of Change

DEECO work activities at client’s facility may impact on the operation of a PSM regulated process.

The DEECO project manager/field team leader and the client’s facility representative will perform

an initial process hazard analysis (hazard evaluation) on processes covered. The process hazard

analysis shall be appropriate to the complexity of the process and shall identify, evaluate, and control

the hazards involved in the process as they relate to DEECO’s work activities. The client’s facility

representative shall determine and document the priority order for conducting process hazard

analyses based on a rationale which includes such considerations as extent of the process hazards,

number of potentially affected employees, age of the process, and operating history of the process.

The process hazard analysis must be conducted before any work by DEECO is conducted.
DEECO Health and Safety Plan Page 21 January 2010

2.20 Scaffolding

Scaffold Erection and Inspection

It is DEECO’s policy not to erect scaffolding. Scaffolding is typically the responsibility of the

client. Scaffolds shall be designed by a qualified person and shall be constructed and loaded in

accordance with that design. Scaffolds shall be erected, moved, dismantled, or altered only under

the supervision and direction of a competent person qualified in scaffold erection, moving,

dismantling or alteration. Such activities shall be performed only by experienced and trained

employees selected for such work by the competent person.

Each day before using any scaffolding, ensure that the scaffolding has been inspected by a person

qualified in scaffold inspection. 

General Requirements for Scaffolding Use

1. The footing or anchorage for scaffolds shall be sound, rigid and capable of carrying the

maximum intended load without settling or displacement.

2. Guardrails and toe-boards shall be installed on all open sides and ends of scaffold platforms

more than four feet above the ground or floor.

3. Scaffolds shall be provided with an access ladder or equivalent safe access.

4. Employees shall not climb or work from scaffold handrails, mid-rails or brace members.

5. When free-standing manually propelled mobile scaffolds are used, the height shall not

exceed four times the minimum base dimension.

a.Employees shall not ride on mobile scaffolds when they are being moved.

6. All scaffolds shall be inspected by a competent person prior to use and shall be acceptancetagged.

7. Employees who erect scaffolds shall be trained in the proper means of building scaffolds.

8. Employees using scaffolds shall be trained in the safe use of scaffolds.

The project manager/field team leader must ensure that all scaffolding is erected in accordance with

OSHA regulations and the items listed above. 

The project manager/field team leader must check with client's representative to see if additional fall

protection is required when working on scaffolding.

Scaffold Use Training

DEECO shall have each employee who performs work while on a scaffold trained by a person

qualified in the subject matter to recognize the hazards associated with the type of scaffold being

used and to understand the procedures to control or minimize those hazards. The training shall

include the following areas, as applicable:

1. The nature of any electrical hazards, fall hazards and falling object hazards in the work area;

2. The correct procedures for dealing with electrical hazards and for erecting, maintaining, and

disassembling the fall protection systems and falling object protection systems being used;
DEECO Health and Safety Plan Page 22 January 2010

3. The proper use of the scaffold, and the proper handling of materials on the scaffold; and

4. The maximum intended load and the load-carrying capacities of the scaffolds used.

Additional training will be provided when changes in the types of scaffolds, fall protection, falling

object protection, or other equipment present a hazard about which an employee has not been

previously trained or when inadequacies in an affected employee's work involving scaffolds indicate

that the employee has not retained the requisite proficiency.

2.21 Stairways and Ladders

With regards to stairways and ladders, employees should follow 29 CFR 1910.25, 26, and 27,

"Portable Wood Ladders, "Portable Metal Ladders, and Fixed Ladders", and 1926 Subpart X,

"Stairways and Ladders".

General Requirements

1. A stairway or ladder shall be provided at all personnel points of access where there is a break

in elevation of 19 inches or more, and no ramp, runway, sloped embankment or personnel

hoist is provided.

2. A double-cleated ladder or two or more separate ladders shall be provided when ladders are

the only means of access or egress from a working area for 25 or more employees, or when

the ladder is to serve simultaneous two-way traffic.

3. When a building or structure has only one point of access between levels, that point of access

shall be kept clear to permit free passage of employees.

Stairways

1. Stairways that will not be a permanent part of the structure on which construction work is

being performed shall have landings of not less than 30 inches in the direction of travel and

extend at least 22 inches in width at every 12 feet or less of vertical rise.

2. Riser height and tread depth shall be uniform within each flight of stairs.

3. Where doors or gates open directly on a stairway, a platform shall be provided, and the swing

of the door shall not reduce the effective width of the platform to less than 20 inches.

4. Slippery conditions on stairways shall be eliminated before the stairways are used to reach

other levels.

5. Except during stairway construction, foot traffic shall be prohibited on skeleton metal stairs

where the treads and landings are to be filled in at a later date, unless the stairs are fitted with

secured temporary treads and landings long enough to cover the entire tread and landing area.

6. Stairways having four or more risers or rising more than 30 inches, whichever is less, shall

be equipped with at least one handrail and one system along each unprotected side or edge.

7. Stairrails shall be not less than 36 inches from the upper surface of the strairrail system to the

surface of the tread.

8. Mid-rails, screens, mesh, intermediate vertical members, or equivalent intermediate structural

members, shall be provided between the top rail of the stairrail system and the stair\way

steps.
DEECO Health and Safety Plan Page 23 January 2010

9. Handrails and the top rails of stairrail systems shall be capable of withstanding a force of at

least 200 pounds applied within two inches of the top edge, in any downward or outward

direction, at any point along the top edge.

10. Fixed stairways shall conform to the requirements of 29 CFR 1919.24 "Fixed Industrial

Stairs".

Ladders

1. Portable ladders shall be capable of supporting at least four times the maximum intended

load.

2. Portable metal or conductive ladders shall not be used near energized lines or equipment

except as may be necessary in specialized work such as high voltage substations where nonconductive ladders might present a greater hazard than conductive ladders. Conductive or

metal ladders shall be prominently marked a conductive and all necessary precautions shall

be taken when used in specialized work.

3. Ladder rungs, cleats and steps shall be parallel, level and uniformly spaced when the ladder

is in position for use.

4. The minimum clear distance between side rails for all portable ladders shall be 11.5 inches.

5. The following requirements apply to the use of all ladders, including job-made ladders.

a. Ladders used for access to an upper landing surface, shall have side rails that extend

at least three feet above the landing surface.

b. Ladders shall be maintained free of oil, grease and other slipping hazards.

c. Ladders shall be used only for the purpose for which they were designed.

d. Non-self-supporting ladders shall be used at an angle such that the horizontal

distance from the top support to the foot of the ladder is approximately one-quarter

of the working length of the ladder.

e. Non-self-supporting ladders shall be tied off or otherwise secured to prevent

accidental displacement.

f. When ascending or descending a ladder, the user shall face the ladder and shall use

at least one hand to grasp the ladder. The user shall not carry any object or load that

could cause him/her to lose balance and fall.

6. Ladders with structural defects, such as broken or missing rungs, shall be tagged DO NOT

USE, and shall be withdrawn from service.

7. Ladders will be inspected by a competent person and approved for use before being put into

service. Each user shall visually inspect ladder before using.

8. Ladders placed in any location where they can be displaced by workplace activities or traffic,

shall have warning signs posted.

Extension Ladders

1. After the extension section has been raised to desired height, the safety latches must be

engaged and the extension rope secured to a rung on the base section of the ladder before use.

2. Extension ladder sections are not to be used separately.

Stepladders

1. Must be set level on all four feet, with spreaders locked on place. Do not use as a straight

ladder.
DEECO Health and Safety Plan Page 24 January 2010

2. When used close to the edge of an elevated platform, roof or floor opening, and when

location requirements so specify, they must be tied off, and employees using such a

stepladder shall wear fall-arresting equipment.

3. Employees using stepladders shall stand so that their waists are below the top of the ladder.

The President shall ensure that all employees are trained in the proper use of ladders. 

2.22 Travel Safety

When driving any DEECO vehicle, or when driving your own personal vehicle when performing

DEECO related work, employees must:

# Obey all traffic rules and regulations.

# Obey all traffic rules on a plant site.

# Turn off vehicle and set brake when leaving vehicle.

# Use horn at blind driveways or intersections with an obstructive view.

# Have a valid North Carolina license to operate a DEECO vehicle and trailer.

# Never pick up hitchhikers.

# Perform a pre-trip check of vehicle(s) lights, horns, brakes, oil, etc.

2.23 Thermal Stress

Thermal stress to the body can be caused when the body temperature is not in balance between body

heat production and heat loss to the surrounding environment. Heat stress is caused when the body

is unable to sufficiently cool the body, and cold stress is possible when the body is unable to

sufficiently heat the body.

Heat Stress

Heat stress is a general term used to describe various degrees of heat illness. The temperature of the

body is a function of the amount of heat it produces and the amount of heat it can lose. When the

temperature of the environment approaches the body temperature, it becomes increasingly difficult

for the body to lose heat. Heat illness is possible when the body is not able to sufficiently cool itself.

The body can lose heat to the environment by three mechanisms. The most important is convection.

This is when the temperature of the skin is higher than that of the surrounding atmosphere.

Conduction is the transfer of heat from the body to a solid or liquid. An example would be the

immediate cooling of your face on a hot day by splashing cold water on it. Both convection and

conduction can also be negative, meaning that if the atmosphere or material in contact with the body

is warmer than the body itself, heat can be transferred to the body.

The third, and comparably small, mechanism is respiration. This is the warming and saturation of

respired air while in the lungs.

Effects of Heat

The body possesses two physiological responses which enable it to lose heat. The first is the dilation

(enlargement) of the blood vessels near the skin surface. This increases the flow of blood,

transferring heat to the skin. The skin temperature will increase, and is cooled by either convection

on conduction.
DEECO Health and Safety Plan Page 25 January 2010

The second response is sweating. Sweating occurs when the increase in blood flow to the skin does

not achieve the desired cooling effect. Heat is lost when sweat is evaporated from the body.

Heat Illness

Heat illness can be caused by either elevated body or skin temperatures. Elevated body temperatures

can result in heat exhaustion, heat cramps, and heat stroke. Elevated skin temperatures can cause

skin-tissue damage.

Heat Exhaustion

Heat exhaustion is caused by circulatory failure, where the amount of blood returned to the heart is

significantly reduced. Symptoms of heat exhaustion are fatigue, headache, dizziness, loss of

appetite, nausea, abdominal pain, vomiting, shortness of breath, and pulse rates in excess of 150

beats per minute. Heat exhaustion can result in poor judgement, irritability, and possibly fainting.

A person suffering from heat exhaustion can usually recover very quickly if he/she is removed to a

cool place and allowed to lie down.

Heat Cramps 

Heat cramps are muscle spasms which usually occur in the arms, legs, back and abdomen. This is

due to excessive loss of salt from sweating. Heat cramps can be prevented by taking extra salt when

heavy work is carried out. It is recommended that employees do not take salt tablets, but rather

ensure that they eat at regular intervals during the course of the work, Extra salt can by added to the

body through eating.

Heat Stroke

The most serious heat illness is heat stroke. When the body temperature reaches a certain level,

sweating may stop. This will cause the body temperature to increase to critical levels. Such an

increase in body temperature can cause denaturization of proteins, enzyme degradation, changes in

the viscosity of cell protoplasm, and alterations in the physical structure of the cell membranes.

Tissue damage and death are possible.

Immediate medical attention is necessary for individuals suffering from heat stroke in order to avoid

irreversible damage to the brain. The individual should be wrapped in cool, wet sheets. Immersion

in a cold bath is not recommended, since a too rapid decrease in the body temperature may result in

tissue damage.

Precautions

1. Water intake must equal the amount of water lost due to sweating and excretion. In hot

environments, water intake must be forced since the body's normal thirst mechanism is not

adequate to force the individual to drink. Continuous sweat rates of 1 to 2 liters per hours

are not unusual.

2. Salt is lost during sweating. Additions of small amounts of salt to food may be necessary.

3. Most importantly, frequent, short breaks during strenuous activities allows the body to better

adapt to the hot environment than infrequent long breaks. By taking shorter breaks, there is

less cumulative fatigue and less demand on the heart and respiration.

4. It is possible for the body to acclimatize to hot environments. This may happen only if

successive days are spent in the hot environment (usually between 4 to 7). 
DEECO Health and Safety Plan Page 26 January 2010

Cold Stress

In cold environments, the body must increase its metabolic heat production. In general, -30 EF is

the lower limit for prolonged work. Unlike hot environments, individuals do not acclimatize

(physiologically adapt) to cold environments.

The wind-chill temperature, rather than the ambient temperature, best describe a cold environment.

Wind velocity adds to the rate of body cooling.

Cold Illness

Hypothermia

Hypothermia is a general cooling of the body temperature. Hypothermia can occur in environments

above 32 EF. Symptoms include excessive shivering, and numbness in extremities. The individual

should be moved to a warm environment. Alcohol should not be consumed, since this will cause

the blood vessel to dilate, resulting in excessive body heat loss. Hot, non-alcoholic beverages should

be administered.

Frost Bite

Frost bite can be either superficial or can penetrate below the skin. Superficial frost bite can be

easily treated by warming the exposed skin with hands or other warmer part of the body (e.g. placing

hands under armpits). This will gradually warm the skin. Rapid warming (exposure to fire, soaking

in cold water etc.) is not recommended since damage to the skin tissue can occur. It is important to

note that pain will occur as the skin is thawed.

When frost bite extends below the surface of the skin (from prolonged exposure), it is essential to

get immediate medical attention.

Precautions

1. Individuals should eat balanced meals and replace body liquids regularly. Dehydration is as

prevalent in cold environments as it is in hot environments. Warm liquids are preferable

since they do not have to be warmed by the body after being consumed.

2. Proper protective clothing should be worn when exposed to cold environments. 

3 Dexterity and judgement are both diminished in cold environments.

2.24 Welding and Cutting

DEECO employees shall not perform any welding or cutting on a project site. The project

manager/field team leader shall ensure that the client contracts such work with qualified individuals.

DEECO employees shall leave the immediate area during any welding or cutting operations.

2.26 Lockout/Tagout (LOTO)

Lockout/Tagout (LOTO) refers to specific practices and procedures to safeguard employees from

the unexpected energization or startup of machinery and equipment, or the release of hazardous

energy during service or maintenance activities. Under no circumstance should DEECO

employee’s participate in LOTO. Should any LOTO be necessary at a client’s facility, all LOTO

procedures are to be handled by the client or their representative.
DEECO Health and Safety Plan Page 27 January 2010

2.27 Fall Protection

2.27.1 Determining When Fall Protection Must be Provided

DEECO shall determine if the walking/working surfaces on which its employees are to work have

the strength and structural integrity to support employees safely. Employees shall be allowed to work

on those surfaces only when the surfaces have the requisite strength and structural integrity.

Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected

side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by

the use of guardrail systems, safety net systems, or personal fall arrest systems.

Hoist Areas

Each employee in a hoist area shall be protected from falling 6 feet (1.8 m) or more to lower levels

by guardrail systems or personal fall arrest systems. If guardrail systems, [or chain, gate, or guardrail]

or portions thereof, are removed to facilitate the hoisting operation (e.g., during landing of

materials), and an employee must lean through the access opening or out over the edge of the access

opening (to receive or guide equipment and materials, for example), that employee shall be protected

from fall hazards by a personal fall arrest system.

Holes

Each employee on walking/working surfaces shall be protected from falling through holes (including

skylights) more than 6 feet (1.8 m) above lower levels, by personal fall arrest systems, covers, or

guardrail systems erected around such holes.

Each employee on a walking/working surface shall be protected from tripping in or stepping into or

through holes (including skylights) by covers.

Each employee on a walking/working surface shall be protected from objects falling through holes

(including skylights) by covers.

Formwork and Reinforcing Steel

Each employee working on the face of formwork or reinforcing steel shall be protected from falling

6 feet (1.8 m) or more to lower levels by personal fall arrest systems, safety net systems, or

positioning device systems.

Ramps, Runways, and Other Walkways

Each employee on ramps, runways, and other walkways shall be protected from falling 6 feet (1.8

m) or more to lower levels by guardrail systems.
DEECO Health and Safety Plan Page 28 January 2010

Excavations

Each employee at the edge of an excavation 6 feet (1.8 m) or more in depth shall be protected from

falling by guardrail systems, fences, or barricades when the excavations are not readily seen because

of plant growth or other visual barrier.

Each employee at the edge of a well, pit, shaft, and similar excavation 6 feet (1.8 m) or more in depth

shall be protected from falling by guardrail systems, fences, barricades, or covers.

Dangerous Equipment

Each employee less than 6 feet (1.8 m) above dangerous equipment shall be protected from falling

into or onto the dangerous equipment by guardrail systems or by equipment guards.

Each employee 6 feet (1.8 m) or more above dangerous equipment shall be protected from fall

hazards by guardrail systems, personal fall arrest systems, or safety net systems.

Overhand Bricklaying and Related Work

Currently, DEECO does not perform overhand bricklaying, so any fall protection programs related

to overhand brick are not applicable.

Working on Roofs

Each employee engaged in any activities on low-slope roofs (slope less than 4 in 12), with

unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling

by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning

line system and guardrail system, warning line system and safety net system, or warning line system

and personal fall arrest system, or warning line system and safety monitoring system.

Each employee on a steep roof (slope greater than 4 in 12) with unprotected sides and edges 6 feet

(1.8 m) or more above lower levels shall be protected from falling by guardrail systems with

toeboards, safety net systems, or personal fall arrest systems.

Precast Concrete Erection

Currently, DEECO does not perform precast concrete erection, so any fall protection programs

related to precast concrete erection are not applicable.

Residential Construction

Currently, DEECO does not perform residential construction, so any fall protection programs related

to residential construction are not applicable.
DEECO Health and Safety Plan Page 29 January 2010

Wall Openings

Each employee working on, at, above, or near wall openings (including those with chutes attached)

where the outside bottom edge of the wall opening is 6 feet (1.8 m) or more above lower levels and

the inside bottom edge of the wall opening is less than 39 inches (1.0 m) above the walking/working

surface, shall be protected from falling by the use of a guardrail system, a safety net system, or a

personal fall arrest system.

Walking/Working Surfaces Not Otherwise Addressed (e.g Man Lifts)

When operating or working on any man lifts that fall under the ANSI standard definition that

includes certain vehicle-mounted elevating and rotating work platforms, namely "extensible boom

platforms," "aerial ladders," "articulating boom platforms," "vertical towers," and "a combination

of any of the above.", DEECO employees shall be protected from falling by a personal fall arrest

system.

For all other walking/working surfaces not otherwise addressed, each employee on a

walking/working surface 6 feet (1.8 m) or more above lower levels shall be protected from falling

by a guardrail system, safety net system, or personal fall arrest system.

Protection from Falling Objects

When an employee is exposed to falling objects, the employer shall have each employee wear a hard

hat and shall erect toeboards, screens, or guardrail systems to prevent objects from falling from

higher levels, erect a canopy structure and keep potential fall objects far enough from the edge of the

higher level so that those objects would not go over the edge if they were accidentally displaced; or,

barricade the area to which objects could fall, prohibit employees from entering the barricaded area,

and keep objects that may fall far enough away from the edge of a higher level so that those objects

would not go over the edge if they were accidentally displaced.

The project manager/field team leader must check with client's representative to see if additional

barricade procedures specific to their facility are required.

2.27.2 Guidelines for Fall Protection

The DEECO project manager/field team in conjunction with the client's representative shall

determine when additional fall protection is required.

The client shall provide and install all Guard Rail Systems, Safety Net Systems, Positioning Device

Systems and Warning Line Systems required for DEECO an employee, and shall comply with all

other pertinent requirements of described below before that employee begins the work that

necessitates the fall protection.

Guardrail Systems 

Top edge height of top rails, or equivalent guardrail system members, shall be 42 inches (1.1 m) plus

or minus 3 inches (8 cm) above the walking/working level. When conditions warrant, the height of
DEECO Health and Safety Plan Page 30 January 2010

the top edge may exceed the 45-inch height, provided the guardrail system meets all other criteria

of this paragraph.

Note: When employees are using stilts, the top edge height of the top rail, or equivalent member,

shall be increased an amount equal to the height of the stilts.

Midrails, screens, mesh, intermediate vertical members, or equivalent intermediate structural

members shall be installed between the top edge of the guardrail system and the walking/working

surface when there is no wall or parapet wall at least 21 inches (53 cm) high.

Midrails, when used, shall be installed at a height midway between the top edge of the guardrail

system and the walking/working level.

Screens and mesh, when used, shall extend from the top rail to the walking/working level and along

the entire opening between top rail supports.

Intermediate members (such as balusters), when used between posts, shall be not more than 19

inches (48 cm) apart.

Other structural members (such as additional midrails and architectural panels) shall be installed

such that there are no openings in the guardrail system that are more than 19 inches (.5 m) wide.

Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds

(890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at

any point along the top edge.

When the 200 pound (890 N) test load specified above is applied in a downward direction, the top

edge of the guardrail shall not deflect to a height less than 39 inches (1.0 m) above the

walking/working level.

Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural

members shall be capable of withstanding, without failure, a force of at least 150 pounds (666 N)

applied in any downward or outward direction at any point along the midrail or other member.

Guardrail systems shall be so surfaced as to prevent injury to an employee from punctures or

lacerations, and to prevent snagging of clothing.

The ends of all top rails and midrails shall not overhang the terminal posts, except where such

overhang does not constitute a projection hazard.

Steel banding and plastic banding shall not be used as top rails or midrails.

Top rails and midrails shall be at least one-quarter inch (0.6 cm) nominal diameter or thickness to

prevent cuts and lacerations. If wire rope is used for top rails, it shall be flagged at not more than 6-

foot intervals with high-visibility material.

When guardrail systems are used at hoisting areas, a chain, gate or removable guardrail section shall

be placed across the access opening between guardrail sections when hoisting operations are not

taking place.
DEECO Health and Safety Plan Page 31 January 2010

When guardrail systems are used at holes, they shall be erected on all unprotected sides or edges of

the hole.

When guardrail systems are used around holes used for the passage of materials, the hole shall have

not more than two sides provided with removable guardrail sections to allow the passage of

materials. When the hole is not in use, it shall be closed over with a cover, or a guardrail system shall

be provided along all unprotected sides or edges.

When guardrail systems are used around holes which are used as points of access (such as

ladderways), they shall be provided with a gate, or be so offset that a person cannot walk directly into

the hole.

Guardrail systems used on ramps and runways shall be erected along each unprotected side or edge.

Manila, plastic or synthetic rope being used for top rails or midrails shall be inspected as frequently

as necessary to ensure that it continues to meet the strength requirements of paragraph (b)(3) of this

section.

Safety Net Systems

Safety nets shall be installed as close as practicable under the walking/working surface on which

employees are working, but in no case more than 30 feet (9.1 m) below such level. When nets are

used on bridges, the potential fall area from the walking/working surface to the net shall be

unobstructed.

Safety nets shall extend outward from the outermost projection of the work surface as follows:

Vertical distance from working level to

horizontal plane of net

Minimum required horizontal distance of

outer edge of net from the edge of the

working surface

Up to 5 feet 8 feet

More than 5 feet up to 10 feet 10 feet

More than 10 feet 13 feet

Safety nets shall be installed with sufficient clearance under them to prevent contact with the surface

or structures below when subjected to an impact force equal to the drop test described below. Safety

nets and their installations shall be capable of absorbing an impact force equal to that produced by

the drop test described below.

Except as described below, safety nets and safety net installations shall be drop-tested at the jobsite

after initial installation and before being used as a fall protection system, whenever relocated, after

major repair, and at 6-month intervals if left in one place. The drop-test shall consist of a 400 pound

(180 kg) bag of sand 30 + or - 2 inches (76 + or - 5 cm) in diameter dropped into the net from the

highest walking/working surface at which employees are exposed to fall hazards, but not from less

than 42 inches (1.1 m) above that level.
DEECO Health and Safety Plan Page 32 January 2010

When the employer can demonstrate that it is unreasonable to perform the drop-test, the employer

(or a designated competent person) shall certify that the net and net installation is in compliance with

the provisions of paragraphs (c)(3) and (c)(4)(i) of this section by preparing a certification record

prior to the net being used as a fall protection system. The certification record must include an

identification of the net and net installation for which the certification record is being prepared; the

date that it was determined that the identified net and net installation were in compliance with

paragraph (c)(3) of this section and the signature of the person making the determination and

certification. The most recent certification record for each net and net installation shall be available

at the jobsite for inspection.

Defective nets shall not be used. Safety nets shall be inspected at least once a week for wear,

damage, and other deterioration. Defective components shall be removed from service. Safety nets

shall also be inspected after any occurrence which could affect the integrity of the safety net system.

Materials, scrap pieces, equipment, and tools which have fallen into the safety net shall be removed

as soon as possible from the net and at least before the next work shift.

The maximum size of each safety net mesh opening shall not exceed 36 square inches (230 cm) nor

be longer than 6 inches (15 cm) on any side, and the opening, measured center-to-center of mesh

ropes or webbing, shall not be longer than 6 inches (15 cm). All mesh crossings shall be secured to

prevent enlargement of the mesh opening.

Each safety net (or section of it) shall have a border rope for webbing with a minimum breaking

strength of 5,000 pounds (22.2 kN).

Connections between safety net panels shall be as strong as integral net components and shall be

spaced not more than 6 inches (15 cm) apart.

Personal Fall Arrest Systems

Personal fall arrest systems shall consist of a full body harness. Body belts are not acceptable as part

of a personal fall arrest system except in a positioning device system as described below.

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall

have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to

interfacing parts of the system.

Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds (22.2 kN) and shall

be proof-tested to a minimum tensile load of 3,600 pounds (16 kN) without cracking, breaking, or

taking permanent deformation.

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent

unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected

member, or shall be a locking type snaphook designed and used to prevent disengagement of the

snaphook by the contact of the snaphook keeper by the connected member. Only locking type

snaphooks shall be used.
DEECO Health and Safety Plan Page 33 January 2010

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall

not be engaged directly to webbing, rope or wire rope, to each other, to a dee-ring to which another

snaphook or other connector is attached, to a horizontal lifeline; or to any object which is

incompatibly shaped or dimensioned in relation to the snaphook such that unintentional

disengagement could occur by the connected object being able to depress the snaphook keeper and

release itself.

On suspended scaffolds or similar work platforms with horizontal lifelines which may become

vertical lifelines, the devices used to connect to a horizontal lifeline shall be capable of locking in

both directions on the lifeline. Horizontal lifelines shall be designed, installed, and used, under the

supervision of a qualified person, as part of a complete personal fall arrest system, which maintains

a safety factor of at least two.

Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds (22.2 kN).

Lifelines shall be protected against being cut or abraded. Self-retracting lifelines and lanyards which

automatically limit free fall distance to 2 feet (0.61 m) or less shall be capable of sustaining a

minimum tensile load of 3,000 pounds (13.3 kN) applied to the device with the lifeline or lanyard

in the fully extended position.

Self-retracting lifelines and lanyards which do not limit free fall distance to 2 feet (0.61 m) or less,

ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum

tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully

extended position.

Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and

body harnesses shall be made from synthetic fibers.

Anchorages used for attachment of personal fall arrest equipment shall be independent of any

anchorage being used to support or suspend platforms and capable of supporting at least 5,000

pounds (22.2 kN) per employee attached, or shall be designed, installed, and used as part of a

complete personal fall arrest system which maintains a safety factor of at least two and under the

supervision of a qualified person.

Personal fall arrest systems, when stopping a fall, shall limit maximum arresting force on an

employee to 900 pounds (4 kN) when used with a body belt, limit maximum arresting force on an

employee to 1,800 pounds (8 kN) when used with a body harness, be rigged such that an employee

can neither free fall more than 6 feet (1.8 m), nor contact any lower level, bring an employee to a

complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m)

and, have sufficient strength to withstand twice the potential impact energy of an employee free

falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is

less.

The attachment point of the body belt shall be located in the center of the wearer's back. The

attachment point of the body harness shall be located in the center of the wearer's back near shoulder

level, or above the wearer's head.

Body belts, harnesses, and components shall be used only for employee protection (as part of a

personal fall arrest system or positioning device system) and not to hoist materials.
DEECO Health and Safety Plan Page 34 January 2010

Personal fall arrest systems and components subjected to impact loading shall be immediately

removed from service and shall not be used again for employee protection until inspected and

determined by a competent person to be undamaged and suitable for reuse.

The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that

employees are able to rescue themselves.

Personal fall arrest systems shall be inspected prior to each use for wear, damage and other

deterioration, and defective components shall be removed from service.

Body belts shall be at least one and five-eighths (1 5/8) inches (4.1 cm) wide.

Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to

hoists. When a personal fall arrest system is used at hoist areas, it shall be rigged to allow the

movement of the employee only as far as the edge of the walking/working surface.

Positioning Device Systems

Positioning device systems shall be rigged such that an employee cannot free fall more than 2 feet

(.9 m). Positioning devices shall be secured to an anchorage capable of supporting at least twice the

potential impact load of an employee's fall or 3,000 pounds (13.3 kN), whichever is greater.

Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials and shall

have a corrosion-resistant finish. All surfaces and edges shall be smooth to prevent damage to

interfacing parts of this system. Connecting assemblies shall have a minimum tensile strength of

5,000 pounds (22.2 kN).

Dee-rings and snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds (16 kN)

without cracking, breaking, or taking permanent deformation. 

Snaphooks shall be sized to be compatible with the member to which they are connected to prevent

unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected

member, or shall be a locking type snaphook designed and used to prevent disengagement of the

snaphook by the contact of the snaphook keeper by the connected member. As of January 1, 1998,

only locking type snaphooks shall be used.

Unless the snaphook is a locking type and designed for the following connections, snaphooks shall

not be engaged directly to webbing, rope or wire rope, to each other, to a dee-ring to which another

snaphook or other connector is attached, to a horizontal lifeline; or to any object which is

incompatibly shaped or dimensioned in relation to the snaphook such that unintentional

disengagement could occur by the connected object being able to depress the snaphook keeper and

release itself.

Positioning device systems shall be inspected prior to each use for wear, damage, and other

deterioration, and defective components shall be removed from service.

Body belts, harnesses, and components shall be used only for employee protection (as part of a

personal fall arrest system or positioning device system) and not to hoist materials.
DEECO Health and Safety Plan Page 35 January 2010

Warning Line Systems

Warning line systems shall be erected around all sides of the roof work area. When mechanical

equipment is not being used, the warning line shall be erected not less than 6 feet (1.8 m) from the

roof edge. When mechanical equipment is being used, the warning line shall be erected not less than

6 feet (1.8 m) from the roof edge which is parallel to the direction of mechanical equipment

operation, and not less than 10 feet (3.1 m) from the roof edge which is perpendicular to the direction

of mechanical equipment operation.

Points of access, materials handling areas, storage areas, and hoisting areas shall be connected to the

work area by an access path formed by two warning lines. When the path to a point of access is not

in use, a rope, wire, chain, or other barricade, equivalent in strength and height to the warning line,

shall be placed across the path at the point where the path intersects the warning line erected around

the work area, or the path shall be offset such that a person cannot walk directly into the work area.

Warning lines shall consist of ropes, wires, or chains, and supporting stanchions erected as follows:

1. The rope, wire, or chain shall be flagged at not more than 6-foot (1.8 m) intervals with highvisibility material;

2. The rope, wire, or chain shall be rigged and supported in such a way that its lowest point

(including sag) is no less than 34 inches (.9 m) from the walking/working surface and its

highest point is no more than 39 inches (1.0 m) from the walking/working surface;

3. After being erected, with the rope, wire, or chain attached, stanchions shall be capable of

resisting, without tipping over, a force of at least 16 pounds (71 N) applied horizontally

against the stanchion, 30 inches (.8 m) above the walking/working surface, perpendicular to

the warning line, and in the direction of the floor, roof, or platform edge;

4. The rope, wire, or chain shall have a minimum tensile strength of 500 pounds (2.22 kN), and

after being attached to the stanchions, shall be capable of supporting, without breaking, the

loads applied to the stanchions as described above; and

5. The line shall be attached at each stanchion in such a way that pulling on one section of the

line between stanchions will not result in slack being taken up in adjacent sections before the

stanchion tips over.

No employee shall be allowed in the area between a roof edge and a warning line unless the

employee is performing roofing work in that area.

Mechanical equipment on roofs shall be used or stored only in areas where employees are protected

by a warning line system, guardrail system, or personal fall arrest system.

Controlled Access Zone

When used to control access to areas where leading edge and other operations are taking place the

controlled access zone shall be defined by a control line or by any other means that restricts access.
DEECO Health and Safety Plan Page 36 January 2010

When control lines are used, they shall be erected not less than 6 feet (1.8 m) nor more than 25 feet

(7.7 m) from the unprotected or leading edge, except when erecting precast concrete members.

DEECO does not erecting precast concrete members. The control line shall extend along the entire

length of the unprotected or leading edge and shall be approximately parallel to the unprotected or

leading edge. The control line shall be connected on each side to a guardrail system or wall.

Additional control lines shall be erected at each end to enclose the controlled access zone.

Control lines shall consist of ropes, wires, tapes, or equivalent materials, and supporting stanchions.

Each line shall be flagged or otherwise clearly marked at not more than 6-foot (1.8 m) intervals with

high-visibility material. Each line shall be rigged and supported in such a way that its lowest point

(including sag) is not less than 39 inches (1 m) from the walking/working surface and its highest

point is not more than 45 inches (1.3 m) from the walking/working surface. Each line shall have a

minimum breaking strength of 200 pounds (.88 kN).

Safety Monitoring Systems

DEECO shall designate a competent person as the safety monitor. The safety monitor will monitor

the safety of other employees. The safety monitor shall be competent to recognize fall hazards. The

safety monitor shall warn the employee when it appears that the employee is unaware of a fall hazard

or is acting in an unsafe manner. The safety monitor shall be on the same walking/working surface

and within visual sighting distance of the employee being monitored. The safety monitor shall be

close enough to communicate orally with the employee. The safety monitor shall not have other

responsibilities which could take the monitor's attention from the monitoring function.

Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being

used to monitor employees engaged in roofing operations on low-slope roofs. No employee, other

than an employee engaged in roofing work [on low-sloped roofs] or an employee covered by a fall

protection plan, shall be allowed in an area where an employee is being protected by a safety

monitoring system.

Each employee working in a controlled access zone shall be directed to comply promptly with fall

hazard warnings from safety monitors.

Covers

Covers located in roadways and vehicular aisles shall be capable of supporting, without failure, at

least twice the maximum axle load of the largest vehicle expected to cross over the cover. All other

covers shall be capable of supporting, without failure, at least twice the weight of employees,

equipment, and materials that may be imposed on the cover at any one time. All covers shall be

secured when installed so as to prevent accidental displacement by the wind, equipment, or

employees. All covers shall be color coded or they shall be marked with the word "HOLE" or

"COVER" to provide warning of the hazard.

Protection from Falling Objects

Toeboards, when used as falling object protection, shall be erected along the edge of the overhead

walking/working surface for a distance sufficient to protect employees below. Toeboards shall be
DEECO Health and Safety Plan Page 37 January 2010

capable of withstanding, without failure, a force of at least 50 pounds (222 N) applied in any

downward or outward direction at any point along the toeboard. Toeboards shall be a minimum of

3 1/2 inches (9 cm) in vertical height from their top edge to the level of the walking/working surface.

They shall have not more than 1/4 inch (0.6 cm) clearance above the walking/working surface. They

shall be solid or have openings not over 1 inch (2.5 cm) in greatest dimension. Where tools,

equipment, or materials are piled higher than the top edge of a toeboard, paneling or screening shall

be erected from the walking/working surface or toeboard to the top of a guardrail system's top rail

or midrail, for a distance sufficient to protect employees below. Guardrail systems, when used as

falling object protection, shall have all openings small enough to prevent passage of potential falling

objects.

Canopies, when used as falling object protection, shall be strong enough to prevent collapse and to

prevent penetration by any objects which may fall onto the canopy.

Fall Protection Plan

This option is available only to employees engaged in leading edge work that it is infeasible or it

creates a greater hazard to use conventional fall protection equipment. 

The fall protection plan shall be prepared by a qualified person and developed specifically for the

site where the leading edge work, precast concrete work, or residential construction work is being

performed and the plan must be maintained up to date. Any changes to the fall protection plan shall

be approved by a qualified person. A copy of the fall protection plan with all approved changes shall

be maintained at the job site. The implementation of the fall protection plan shall be under the

supervision of a competent person. The fall protection plan shall document the reasons why the use

of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets

systems) are infeasible or why their use would create a greater hazard.

The fall protection plan shall include a written discussion of other measures that will be taken to

reduce or eliminate the fall hazard for workers who cannot be provided with protection from the

conventional fall protection systems. For example, the employer shall discuss the extent to which

scaffolds, ladders, or vehicle mounted work platforms can be used to provide a safer working surface

and thereby reduce the hazard of falling.

The fall protection plan shall identify each location where conventional fall protection methods

cannot be used. These locations shall then be classified as controlled access zones. Where no other

alternative measure has been implemented, the employer shall implement a safety monitoring

system.

The fall protection plan must include a statement which provides the name or other method of

identification for each employee who is designated to work in controlled access zones. No other

employees may enter controlled access zones.

In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the

employer shall investigate the circumstances of the fall or other incident to determine if the fall

protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement

those changes to prevent similar types of falls or incidents.
DEECO Health and Safety Plan Page 38 January 2010

2.27.3 Fall Protection Training Program

DEECO shall provide a training program for each employee who might be exposed to fall hazards.

The program shall enable each employee to recognize the hazards of falling and shall train each

employee in the procedures to be followed in order to minimize these hazards.

DEECO shall assure that each employee has been trained, as necessary, by a competent person

qualified in the nature of fall hazards in the work area, the correct procedures for erecting,

maintaining, disassembling, and inspecting the fall protection systems to be used, the use and

operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems,

safety monitoring systems, controlled access zones, and other protection to be used, the role of each

employee in the safety monitoring system when this system is used, the limitations on the use of

mechanical equipment during the performance of roofing work on low-sloped roofs, the correct

procedures for the handling and storage of equipment and materials and the erection of overhead

protection; and the role of employees in fall protection plans.

Certification of Training

DEECO shall verify compliance with the Fall Protection Training Program by preparing a written

certification record. The written certification record shall contain the name or other identity of the

employee trained, the date(s) of the training, and the signature of the person who conducted the

training or the signature of the employer. If training is conducted by another employer, the

certification record shall indicate the date the employer determined the prior training was adequate

rather than the date of actual training.

The latest training certification shall be maintained.

Retraining

When DEECO has reason to believe that any affected employee who has already been trained does

not have the understanding and skill required by the Fall Protection Training Program, DEECO shall

retrain each such employee. Circumstances where retraining is required include, but are not limited

to, situations where changes in the workplace render previous training obsolete, changes in the types

of fall protection systems or equipment to be used render previous training obsolete, or inadequacies

in an affected employee's knowledge or use of fall protection systems or equipment indicate that the

employee has not retained the requisite understanding or skill.

2.28 Combustible Gas (LEL), Carbon Monoxide, Hydrogen Sulfide, and/or Oxygen

Monitors 

For safe operation around processes involving combustible materials, a hot work permit may be

required. Hot work permits (HWPs) are required for any process where testing activities may

produce an ignition source in a work area in which flammable vapors or gases may be present. To

issue an HWP, a hazard assessment must be performed. To do so, combustible gas and vapor

concentrations must be determined for the work area and job classification in question, then

compared to acceptable standards. These surveys typically involve the use of combustible gas

meters-also called lower explosive limit (LEL) meters. These surveys are conducted by the client

personnel issuing the hot work permits .
DEECO Health and Safety Plan Page 39 January 2010

To perform the surveys properly, the facility will have work instructions and standard operating

procedures (SOPs) developed, implemented and documented. Training in LEL instrument use,

instrument calibration, sampling strategy, continuous or follow-up monitoring, tracking of denied

permits, communication between departments related to the content of processes, documentation of

results, auditing of hot work permit procedures and results, and the continuous improvement of those

SOPs will be addressed. 

In some cases DEECO will be required to provide additional monitoring for LEL, carbon monoxide,

hydrogen sulfide, and/or oxygen. For these situations, DEECO personnel will be trained in LEL,

carbon monoxide, hydrogen sulfide, and/or oxygen instrument use and instrument calibration.

Training in Instrument Use

Thorough, documented training will be performed for the use of LEL, carbon monoxide, hydrogen

sulfide, and/or oxygen meters. Thus, training programs for operators of LEL, carbon monoxide,

hydrogen sulfide, and/or oxygen meters will include:

1. Work instructions for basic instrument use;

2. Theory of instrument operation;

3 Instrument maintenance and calibration; and 

4. Recordkeeping for calibration and maintenance.

Instrument Calibration

The instrument manufacturers detail procedures for calibrating LEL, carbon monoxide, hydrogen

sulfide, and/or oxygen meters will be followed. Calibration includes;

1. Clean air-zero point calibration;

2. Calibration of response with the appropriate span gas;

3. Checking and calibration, for actively pumped meters, of the air flow rate in the system;

4. Fault detection and subsequent maintenance; and

5. Record keeping.

Any decisions made to extend the period between calibrations or to lessen the rigor of calibrations

must first be formally evaluated by qualified persons against the manufacturer's recommendations,

industry best practices and governmental regulations. Requirements for specified, periodic

calibration of zero, span and flow are mandates, not recommendations. This applies for all systems,

but is especially critical for systems used in environments where air contaminants that may degrade

the meter's sensing element may be present.
DEECO Health and Safety Plan Page 40 January 2010

For gases and vapors other than those for which a device was calibrated, the manufacturer's

instructions and correction curves should be consult. Variations in response that may result in

incorrect readings from such interferences as:

1. Oxygen concentration;

2. Gas pressure;

3. Sensor poisons (i.e., silicon, silicates and organic lead, acid gases) and sensor depressants

(i.e., chlorinated hydrocarbons, acid gases); and

4. The fact that no reading will occur, or is even possible, for the detection of combustible

airborne mists or dusts, such as lubricating oils, coal dust or grain dust.

The portion of the calibration that deals with instrument airflow rate must include the blocked flow

alarm must being tested before and after each use. While this is a requirement for all such systems,

it is especially critical for instruments used in dusty environments.

Sampling Strategy

Measurement of values for each atmospheric parameter should be made for at least the minimum

response time of the instrument. When monitoring operations involving a descent into atmospheres

that may be stratified, the atmospheric envelope should be tested a distance of approximately four

feet in the direction of travel and to each side. If a sampling probe is used, the rate of progress

should be slowed to accommodate the sampling speed and detector response .

Any reading greater than zero should be followed by an assessment to:

1. Determine the source of the flammable vapors;

2. Eliminate the source, if possible; and

3. Ensure control of the source so that concentrations will not exceed (at most) 10% of the LEL

at any location where it is possible that an ignition source may be present.

Continuous or Follow-Up Monitoring

Continuous or follow-up monitoring may be required under conditions where the process, sequence

of work instructions or ambient conditions might reasonably be expected to change in a manner that

might increase the concentration of flammable gas or vapor. If conditions change during the course

of the permit period in a way that presents or could present additional hazards, then work will be

terminated until the area or conditions are made safe and permit conditions are re-evaluated.

Processes that may affect the composition, concentration, flow rate or volume, pressure and/or

temperature of flammable liquids, vapors or gases;

1. Processes adjacent to the process at which hot work is being performed;
DEECO Health and Safety Plan Page 41 January 2010

2. Ambient conditions such as temperature, wind direction and wind speed; and 

3. Other factors, such as the presence of uncontrolled vehicular traffic and/or ignition sources.

Documentation of Results (Record Keeping)

Each monitor obtained by DEECO will be assign a unique equipment identification (control) number

and complete records, including periodic performance, calibration and maintenance checks will be

maintained. 

2.29 Emergency Response/Evacuation Program

While at a client’s facility, follow their Emergency Response/Evacuation Program. The project

manager/field team leader will ensure that the employees are aware of the facilities’ Emergency

Response/Evacuation Program. Their plan should address the following;

1. Procedures for reporting a fire or other emergency;

2. Procedures for emergency evacuation, including type of evacuation and exit route

assignments;

3. Procedures to account for all employees after evacuation (head count);

4. Procedures to be followed by employees performing rescue or medical duties; and

5. The name or job title of every employee who may be contacted by employees who need more

information about the plan or an explanation of their duties under the plan.

Otherwise, when working at DEECO’s office, the following Emergency Response/Evacuation

procedures should be followed;

1. Report a fires or other emergencies by dialing 911. Administer first aid and/or CPR if you

trained. Do not attempt to fight any fires unless you have been trained in the use of fire

extinguishers;

2. Should an evacuation be necessary follow the escape route assignments. Exit diagrams are

place throughout the office to identify the escape routes to be followed by employees from

each specific facility location. Assist in the evacuation of any visitors and contractors; 

3. Account for employees after the evacuation to ensure that everyone got out. Designated

employees will sweep areas, checking offices and rest rooms, before being the last to leave

a workplace or conducting a roll call in the assembly area; and

4. Account for any visitors and contractors using the Visitors and Contractors Sign In Log.
DEECO Health and Safety Plan Page 42 January 2010

2.30 Compressed Air Systems

DEECO employees are not allowed to operate pneumatic power tools or use the compressed air

systems, air hoses, or air lines associated with pneumatic power tools.

2.31 Concrete Construction

DEECO employees are not allowed perform any concrete work, as described in OSHA 1926.700-

706.

2.32 Powder-Actuated Tools

DEECO employees are not allowed to use powder-actuated tools, as described in OSHA 1926.302

(e).
DEECO Health and Safety Plan Page 43 January 2010

3.0 Chemical Safety Guidelines

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

safety procedures, Field personnel are to follow the procedures which are more stringent. In all

cases, all OSHA and/or EPA requirements shall be met.

Field personnel are to refer to the Material Safety Data Sheet and chemical labels for specific

procedures and handling requirements. Copies of MSDSs for each chemical used, as well as for each

chemical Field personnel may be exposed to while on a client's site, must be made available. The

client is responsible for ensuring that MSDSs for chemicals used on the work site are available for

review. All Field personnel should refer to these MSDSs and be familiar with the properties and

handling requirements of all chemicals that may be used or encountered.

The required level of personal protective equipment for specific chemical hazards discussed in the

following sections depends on the situations at the work site. Decisions on the appropriate

equipment to be worn should be made by the project manager or coordinator.

The following information is DEECO's Chemical Hygiene Plan. Its intent is to protect laboratory

employees from health hazards associated with the use of hazardous chemicals in our laboratory and

to assure that our laboratory employees are not exposed to substances in excess of the permissible

exposure limits as defined by OSHA in 29 CFR 1910 subpart Z.

The plan is available to all employees fro review and a copy will be located in the Health and Safety

files. The plan will be reviewed annually by the Health and Safety Officer and/or the directors of

DEECO.

The following sections of this document and throughout the manual are standard operating

procedures for which each DEECO employee has received adequate training and direction. If

questions exist for the following information, it may be found throughout this manual or in our

memo file. It is the responsibility of each employee to be aware of DEECO's standard operating

procedures for the following:

Accidents, spills, avoidance of routine exposure, choice of chemicals, eating-drinking-smoking,

equipment and glassware, horseplay, mouth suction, personal apparel, housekeeping, personal

protection, planning, unattended operations, use of the hood, waste disposal and storage, working

alone, corrosives, fires, explosions, low temperature, pressurized and vacuum operations,

compressed gasses, chemical storage.

The following operations shall be performed in the LABORATORY FUME HOOD:

- Use of solvents unless in outdoor work areas

- Use of open flames or burning devices

- Use of any organic or inorganic chemical or compound that is unstable

These include preparation of standards, transfer of solvents, disposal or consolidation of waste 
DEECO Health and Safety Plan Page 44 January 2010

Respirators shall be used in accordance with DEECO's respiratory protection policy and with the

OSHA respirator standard 29 CFR 1910.134. This policy and associated documentation is filed in

the office of the Health and Safety Officer and/or safety files.

Appropriate protective apparel compatible with the required degree of protection for substances

handled shall be used. The Health and Safety Officer is available to advise employees on glove,

gown, eye protection, barrier creams, etc, use. Permeability Charts are available in any safety catalog

such as Lab Safety Supply, or SAFECO. Use of tradenames or references does not indicate a

recommendation or approval of listed products or Companies.

All eyewash stations are clearly marked and identified by the use of green placards and red arrows

leading to the eyewash areas. Employees who need to use the eyewashes are instructed as to their

use and must irrigate for a minimum of 15 minutes and seek medical assistance immediately.

Eyewashes will be inspected by the safety officer every month.

Employees have been issued a memorandum as to the procedures to follow for fires and explosions.

Exit routes are marked in each employee area. 

Fume hoods will be inspected every six months by the Health and Safety Officer. Adequacy of face

velocity will be determined by the use of a propeller anemometer and must reach a minimum of 200

fpm. An employee may request a hood inspection at any time should they suspect a problem with

the hood or ventilation system.

No employee will work with any hazardous chemicals unless they have been instructed by their

project manager or health and safety officer. These chemicals include; carcinogens, explosives,

neurotoxins, reproductive damaging chemicals, or acutely hazardous chemicals.

DEECO shall provide, to affected employees, medical attention including follow-up examinations

which MEDFIRST or another approved medical office determines is necessary under the following

circumstances.

a. whenever an employee develops signs and/or symptoms associated with a hazardous

chemical to which they may have been exposed, the employee shall be provided an

opportunity to receive appropriate medical examination. The employee shall contact the

Health and Safety Officer to initiate the medical program.

b. Where exposure monitoring reveals an exposure level routinely above the OSHA action level

(AL) (or in the absence of an action level, exposure above the OSHA permissible exposure

level (PEL)) for OSHA regulated substances for which there are medical monitoring

requirements, medical surveillance shall be established for that employee. Listed OSHA

standard medical surveillance requirements include the chemical benzene, formaldehyde,

methylene chloride.

c. Whenever an event takes place in the laboratory or work area such as a spill, leak, explosion,

or other occurrence resulting in the likelihood of a hazardous exposure, the affected

employee, laboratory or custodial, shall be provided an opportunity for a medical

consultation. This consultation is for the purpose of determining the need for a medical

examination.
DEECO Health and Safety Plan Page 45 January 2010

All aspects of these examinations are provided by a licensed physician, or supervised by a licensed

physician. These examinations are provided without cost to the employee, without loss of pay, and

at a reasonable time and place.

The Health and Safety Officer who is also the Chemical Hygiene Officer will provide information

to the physician:

1. Identity of the hazardous chemical to which the employee may have been exposed.

2. A description of the conditions of the exposure including exposure date if available

3. A description of the signs and symptoms of exposure that the employee is experiencing (if

any).

The physician's written opinion shall include:

1. Recommendations for future medical follow-up

2. Results of examination and associated tests

3. Any medical condition revealed that may place the employee at increased risk as the result

of a chemical exposure.

4. A statement that the employee has been informed by the physician of the results and told of

any medical conditions that may require additional examination of treatment.

3.1 General Characteristics

Routes of Entry

There are three major routes through which chemicals can enter the body and potentially cause harm.

Inhalation: Contaminants in the air can be absorbed into the bloodstream directly through the

lungs. In this manner, the contaminant can be carried to any organ in the body.

Ingestion: Ingestion of chemicals may severely damage the tissues of the digestive tract, damage

the stomach or other organs. The chemical can be absorbed into the bloodstream, or other body

fluids, and carried to other organs in the body.

Skin Absorption: The skin can act as a protective barrier to many chemical agents. However, many

chemicals can penetrate the skin. In this manner, the chemicals can enter the bloodstream and be

distributed throughout the body. Wounds on the skin (e.g. cuts and abrasions) offer a direct route

for chemicals to enter the bloodstream.

Physical Characteristics of Chemicals

Below are definitions of terms used in the following Chemical Safety Sections. Additional

definitions are located in the Guide to Common MSDS Terms, located in Appendix C.

Gas - a formless fluid which takes the shape of its container.

Vapor - the gaseous form of a substance which is normally a solid or liquid at room

temperature.

Fog - a visible, liquid aerosol.

Mist - a "fog" where the liquid particles are large enough to be individually seen.

Fume - particle formed by the condensation of vaporized solids.
DEECO Health and Safety Plan Page 46 January 2010

Dust - solid particles, capable of temporary suspension in air.

Smoke - airborne particles generated from incomplete combustion processes.

Carcinogen - a substance capable of causing cancer in animals or humans.

Mutagen - a substance capable of changing the genetic material in a living cell.

Fetotoxin - a substance capable of causing death or injury to fetus.

Teratogen - a substance which can cause deformations in a fetus from exposure of a

pregnant female.

Health Hazards

Substances to which field employees may be exposed have the potential to cause severe injury or

illnesses. The degree of injury or illness is a function of the exposure; that is the amount of the

substance and the time that an employee is in contact with it. Below are descriptions of various types

of health hazards that may exist when working with hazardous substances.

Irritant: Several chemicals may be an irritant to the skin, eyes, or respiratory tract. Irritation can

range from mild discomfort to severe and irreversible chemical burns on the skin or eyes. Examples

of irritants include ammonia, acids, bases, and several solvents.

Sensitizer: A chemical that is a sensitizer may not elicit a response after one exposure. After

repeated exposures, however, a severe reaction may occur, not necessarily at the point of contact.

The reaction may be a skin rash, or in the case of toluene diisocyanate, failure of the respiratory

system, Examples of sensitizers are formaldehyde, poison ivy, potassium dichromate.

Narcotic: Narcotics cause a depression of the central nervous system, producing a sleepy or dizzy

effect. Narcotics may make an employee unable to perform his/her work. Other safety hazards arise

when employees affected by a narcotic attempt to continue to work. Most organic solvents can

produce narcotic effects.

Asphyxiant: An asphyxiant reduces the amount of oxygen available for use by the body. This can

cause suffocation, leading to coma or even death. There are two types of asphyxiants. A Simple

Asphyxiant reduces the amount of oxygen in an area. Examples of simple asphyxiants include

carbon dioxide, nitrogen, argon, and other inert gases. A second type of asphyxiant is called a

Chemical Asphyxiant. A chemical asphyxiant enters the body through the lungs, and competes with

oxygen for space in the red blood cells. With these asphyxiants, suffocation can occur even if there

is plenty of oxygen in the room. Examples of chemical asphyxiants include carbon monoxide, and

cyanide gas.

Systemic Poison of Toxin: A systemic poison or toxin is a substance that produces an affect away

from the point of contact. For instance carbon tetrachloride can be inhaled or absorbed through the

skin, but exhibits its major effects upon the liver and kidneys.

It is important to remember that different chemicals react differently with the body. Several

chemicals exhibit more than one effect. The employee must review the MSDS for the specific

chemical he/she is working with to fully understand all of the potential hazards.
DEECO Health and Safety Plan Page 47 January 2010

3.2 Acids

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Acids are corrosive substances having a pH < 7.0.

2. Acid vapors and fumes can cause irritation of the eyes, skin, and respiratory tract.

3. Chemical burns on tissue can occur if acids are allowed to contact skin, eyes, or lungs.

4. Severe gastrointestinal pain and tissue injury can occur if acids are ingested.

Symptoms of Overexposure

Hazards of exposure are mainly from acute (short duration) exposures. Effects of acid fumes

or vapors include eye, throat, nose, or lung irritation. Skin or eye contact with acids may

result in severe chemical burns.

First Aid

In the event that acid comes in contact with your skin or eyes:

# Proceed immediately to the nearest eyewash station. Call for assistance from a coworker if necessary.

# Flush the affected area with copious amounts of water for at least 15 minutes. If

contact was with eye, pull the eyelid up and out, exposing the cornea, while flushing

with water.

# Notify the project manager or coordinator and seek medical attention.

If acid is spilled on your clothing:

# Remove contaminated clothing immediately.

# Flush skin area with water for 15 minutes.

# Notify the manager or coordinator and seek medical attention.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Protective Clothing (Saranex Tyvek Suits)

3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or

Organic Vapor/Acid Gas Cartridges.

4. Eyewear - Minimum of safety glasses with side shields. Recommend chemical splash

goggles.

3.3 Bases

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Bases are corrosive substances having a pH > 7.0.

2. Vapors and fumes generated from bases can cause irritation of the eyes, skin, and respiratory

tract.
DEECO Health and Safety Plan Page 48 January 2010

3. Chemical burns can occur if bases are allowed to contact skin or eyes. Bases can cause

irreversible damage to the eyes, even in dilute concentrations.

4. Severe gastrointestinal pain and tissue injury can occur if bases are ingested.

Symptoms of Overexposure

Hazards of exposure are mainly from acute (short duration ) exposures. Effects of alkali

fumes or vapors include eye, throat, nose, or long irritation. Skin or eye contact with bases

may result in severe chemical burns.

First Aid

In the event that a base comes in contact with your skin or eyes: 

# Proceed immediately to the nearest eyewash station. Call for assistance from a coworker if necessary.

# Flush the affected area with copious amounts of water for at least 15 minutes. If

contact was with eye, pull the eyelid up and out, exposing the cornea.

# Notify the project manager or coordinator and seek medical attention.

If a base is spilled on your clothing:

# Remove contaminated clothing immediately.

# Flush skin area with water for 15 minutes.

# Notify the project manager or coordinator and seek medical attention.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Protective Clothing (Saranex Tyvek Suits)

3. Respiratory Protection - Minimum or a half-mask, air-purifying respirator with Acid Gas or

Organic Vapor/Acid Gas Cartridges.

4. Eyewear - Minimum of safety glasses with side shields. Recommend chemical splash

goggles.

3.4 Compressed Gases

Potential Hazards

Routes of Entry - Inhalation, Contact

1. Cylinders may explode if heated above 135 EF or dropped, damaging the valve stem.

2. Fire Hazards may exist if a Flammable Gas, Oxygen or other oxidizing gas cylinder is placed

near an open flame.

3 Skin and eye burns may result if direct contact with an escaping gas is made.

4. Suffocation can occur if the concentration of a gas is allowed to decrease the percent of

oxygen in an area.

5. If Oxygen is allowed to be released, it may be absorbed into clothing and take as long as 15

minutes to disperse. This could lead to a flash clothing fire if the person comes in contact

with an ignition source.

6. Severe burns may result from skin or eye contact with cryogenic gases.
DEECO Health and Safety Plan Page 49 January 2010

7. Prolonged breathing of oxygen can be toxic.

8. A fire or explosion hazard may exist when using nitrogen and helium, since these gases can

condense oxygen from the air, creating an oxygen-rich environment at the location of the gas.

Symptoms of Overexposure

Symptoms of overexposure to compressed gases depends on the specific gas. Refer to the

MSDS of the gas for this information.

General Handling Procedures

1. Cylinders should be tagged with a FULL, IN USE, or EMPTY Status Tag at all times.

2. Cylinders must have the valve protection cap in place when being moved.

3. Cylinders shall be stored such that they are protected from excessive heat or open flame (125

EF), physical shock, and electrical circuits.

4. Cylinders shall be secured using a chain or strap, to a wall, bench or other firm support.

5. Never completely empty a gas cylinder.

6. Never use oil on regulator valves or connections. Oil can degrade the regulator diaphragm,

contaminate the gas, or be oxidized in air to form explosive products.

7. Use only CGA (Compressed Gas Association) approved regulators and fittings for the

specific gas being used. Do not mix a given regulator with different gases.

8. Do not tamper with manufacturer's safety devices or check valves.

9. Leak-test all fittings and connections using an appropriate leak-test solution.

10. Jewelry should not be worn when handling or using cryogens.

11. If a cylinder should develop a leak:

# Remove all sources of spark or flame.

# Place in exhausted enclosure or remove to a safe outdoor area.

# Identify the cylinder as "Leaking Cylinder". Notify the supplier.

# For Flammable Gases, attach a control valve to the cylinder valve and allow the gas

to escape. Adjust to a moderate discharge rate.

12. If a cylinder containing cryogenic gases is dropped:

# Evacuate area within 100-ft radius of cylinder;

# Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel

relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is

venting gas, do not approach until there is no further discharge.

# When emission from the cylinder has not been noticed for 15 minutes, carefully open

the vent valve and the gas withdrawal valve to empty the cylinder. Move away from

the cylinder after opening valves.

# Once emptied, place in upright position. Write "Dropped Cylinder" on the cylinder

status tag and notify the supplier.

First Aid

If skin or eye contact occurs, flush area with unheated water and apply cold compresses.
DEECO Health and Safety Plan Page 50 January 2010

Personal Protective Equipment

Safety glasses should be worn at a minimum. Cryogenic gloves should be worn if contact with a

cryogenic gas is possible.

3.5 Cryogenic Materials

Cryogenic materials are substances that are kept at very low temperatures (less than 100 EF).

Cryogenics may be liquids or solids. Atmospheric gases, such as nitrogen, oxygen, or hydrogen, that

are cooled to temperatures less than 150 EF become liquified and are examples of cryogenic

materials. "Dry Ice" is another example of a super-cooled gas, carbon dioxide.

Potential Hazards

Routes of Entry - Contact, Inhalation

1. Severe burns may result from skin or eye contact with cryogenic materials.

2. Some liquid gases can deplete the available oxygen in a room Suffocation can result if not

used in a well-ventilated area.

3. Prolonged breathing of pure oxygen may have harmful physiological effects.

4. Nitrogen and helium can condense oxygen from the air, creating an oxygen-rich environment

at the location of the gas. This could be a fire or explosion hazard.

5. Cryogenic gases are stored under high pressure. This creates the same potential hazards as

other compressed gases (see Section 3.4).

6. Hydrogen is extremely flammable and is a fire and explosion hazard.

7. Liquid oxygen, while not flammable itself, does increase the flammability of ordinary

combustibles.

General Handling Procedures

1. When there is the potential for contact with a cryogenic material, a full face shield will be

required. In addition, a lab coat and gloves suitable for cold material handling shall be worn.

2. Jewelry should not be worn when handling or using cryogens.

3. When handling cryogens, trousers should not have cuff.

4. Use tongs to remove objects that are immersed in cryogenic liquids. Never use your hands,

even if wearing gloves!!

5. Use only in well-ventilated areas.

6. Store away from flammable and combustible materials.

7. Do not use near open flame or spark-producing equipment.

Emergency Procedures

1. If skin or eye contact occurs, flush area with unheated water and apply cold compresses.

Notify your supervisor and seek medical attention.

2. If a cylinder containing cryogenic gases is dropped:

# Evacuate area within 100-ft radius of cylinder;
DEECO Health and Safety Plan Page 51 January 2010

# Keeping a safe distance (no less than 50 feet), determine if the cylinder's inner vessel

relief valve is venting, or if the outer vessel bursting disc has ruptured. If either is

venting gas, do not approach until there is no further discharge.

# When emission from the cylinder has not been noticed for 15 minutes, carefully open

the vent valve and the gust withdrawal valve to empty the cylinder. Move away from

the cylinder after opening valves.

# Once emptied, place in upright position. Write "Dropped Cylinder" on the cylinder

status tag and notify the supplier.

3.6 Flammable Liquids and Gases

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Flammable liquids and gases pose significant fire and explosion hazards.

2. Many flammable liquids:

# Can be readily absorbed through the skin.

# Can cause dermatitis.

# Are systemic poisons once in the body.

3. Eye, skin and respiratory tract irritation may occur.

4. Many flammable liquids and gases can produce depression of the central nervous system

(decreases motor response, dizziness, etc.)

Systems of Overexposure

Symptoms of overexposure to flammable liquids and gases will depend on the specific

substance. Refer to the MSDS of the chemical for this information.

General Procedures

1. Keep flammable materials away from open flame, sparks, or excessive heat.

2. Keep away from oxidizing agents such as oxygen.

3. Store in chemical cabinet, isolated from other chemicals.

4. Keep combustible material such as wood, cloth, and paper out of storage cabinets.

5. Do not leave containers of flammable materials in work areas overnight. Return all bottles

to the proper storage cabinet.

6. Flammable liquids and gases should be used only in well ventilated areas.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove

contaminated clothing. Seek medical attention.

2. In the event of a burn; extinguish flames by applying a fire blanket, or rolling on the floor.

Do not attempt to fan out the flames.

3. Use only an approved fire extinguisher to extinguish flames. Do not use water on flammable

liquid fires. Pouring water on these fires may only spread the flames over a wider area.
DEECO Health and Safety Plan Page 52 January 2010

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.

3.7 Organic Solvents

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Solvents can cause skin, eye and respiratory tract irritation.

2. Solvents may cause defatting of the skin, which lessens the ability of the skin to protect

against other chemicals.

3. Some solvents are also systemic toxins and can produce effects on the liver, kidneys, and

other organs if allowed to be absorbed through the skin.

4. Inhalation of solvent vapors may produce narcotic or anesthetic effects, and depression of

the central nervous system.

5. Many organic solvents are also flammable.

Symptoms of Overexposure

Symptoms of overexposure to solvents will depend on the specific substance. Refer to the

MSDS of the chemical for this information.

General Procedures

1. Use solvents only in local exhaust hood or well ventilated areas.

2. Do not continue to work if you feel dizzy or sleepy. Have a co-worker secure your apparatus

(turn off heat, close containers, etc.) and escort you away from the area.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected

clothing.

2. If dizziness occurs from inhalation, get to fresh air.

3. In the event of a spill:

# Turn off all sources of flame or sparks. Keep area well ventilated.

# Small spills can be handled by using a solvent spill kit.

4. Use only an approved fire extinguisher to extinguish flames. Do not use water on liquid

fires. Pouring water on these fires may only spread the flames over a wider area.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.
DEECO Health and Safety Plan Page 53 January 2010

3.8 Oxidizing Agents

Potential Hazards

Routes of Entry - Inhalation, Ingestion, Contact

1. Oxidizing agents can be irritating to skin, eyes, and the respiratory tract.

2. Most oxidizing agents are highly reactive, and may react violently with metals, as well as

other chemicals.

3. Oxidizers are corrosive and can cause burns on skin and eyes.

4. Oxidizers spontaneously evolve oxygen, and therefore may create a fire on explosion hazard

in some environments.

Symptoms of Overexposure

Symptoms of overexposure to solvents will depend on the specific substance. Refer to the

MSDS of the chemical for this information.

General Procedures

1. Do not mix with organic solvents.

2. Always store in unbreakable, inert containers.

3. Do not use cork or rubber stoppers.

4. Respiratory protection is required when handling chlorine or bromine gas.

5. Label containers of oxidizers with the date received, and the date the container was first

opened.

First Aid

1. If skin or eye contact occurs, flush affected area with water for 15 minutes. Remove affected

clothing.

2. In the event of a spill:

# Turn off all spark and open flame sources.

# Cover spill area with a bisulfite solution. Mix well and spray with water. Place

waste in container with water.

3. If a gas leak occurs, remove all sources of spark or flame. Place cylinder in an exhausted

enclosure or remove it to a safe outdoor area as soon as possible.

Personal Protective Equipment

1. Gloves (Disposable Latex or Nitrile)

2. Eyewear - minimum of safety glasses with side shields. Chemical goggles required if there

is a potential for splash.

3.9 Asbestos Awareness

Asbestos is the name applied to six naturally occurring minerals that are mined from the earth.

Because it is so hard to destroy asbestos fibers, the body cannot break them down or remove them

once they are lodged in lung or body tissues. They remain in place where they can cause disease. 

There are three primary diseases associated with asbestos exposure:

Asbestosis 

Lung Cancer 

Mesothelioma 
DEECO Health and Safety Plan Page 54 January 2010

DEECO personnel may be exposed to asbestos while on a client's premises. The most common use

of asbestos at our client’s facilities is insulation on pipes and vessels. Asbestos boiler insulation

does not present a hazard unless the protective covering is cut or damaged in such a way that the

asbestos underneath is actually exposed to the air. The project manager/field team leader will ensure

that the client has identified or provided means to identify asbestos-containing equipment. 

If you do not know whether something is asbestos or not, assume that it is until it is verified

otherwise.

DO NOT DISTURB IT. 

Never...

Drill 

Hammer 

Cut 

Saw 

Break 

Damage 

Move 

Disturb 

...any asbestos-containing materials or suspected materials.

3.10 Benzene Awareness

Benzene is a volatile chemical formed from both natural processes and human activities. Natural

sources of benzene include emissions from volcanoes and forest fires. Benzene is also a natural part

of crude oil, gasoline, and cigarette smoke. Benzene is widely used in the United States, ranking in

the top 20 chemicals for production volume. It is primarily used as a solvent, as a starting material

for the production of other chemicals, and as a gasoline additive. Breathing benzene can cause

drowsiness, dizziness, and unconsciousness; long-term benzene exposure causes effects on the bone

marrow and can cause anemia and leukemia. The Occupational Safety and Health Administration

(OSHA) recognizes benzene as a hazardous material and imposes strict exposure limits in the

workplace. 

It is unlikely that DEECO personnel would be exposed to benzene on a client's premises at levels

above the OSHA permissible exposure limits (1 ppm TWA for 8 hour and 5 ppm STEL for 15

minutes). If the potential for benzene exposure exists, the project manager/field team leader will

ensure that the client has identified regulated areas where the permissible exposure limits could be

exceeded.

DEECO does not use benzene for any sample recovery procedures.

3.11 Hydrogen Sulfide Awareness

Hydrogen sulfide (H2S) is a colorless gas with a powerful nauseating smell of rotten eggs. The odor

is a poor warning property because hydrogen sulfide exposure quickly deadens the sense of smell.

The gas is heavier than air and may collect in low areas such as sewers, pits, tunnels or gullies. High

airborne levels of hydrogen sulfide (between 4.3 and 46.0 percent of gas by volume in the air) may

catch fire if there is a source of ignition. If the gas is burned, toxic products such as sulfur dioxide
DEECO Health and Safety Plan Page 55 January 2010

will be formed. Hydrogen sulfide is incompatible with oxidizing agents, such as nitric acid and

chlorine trifluoride, and may react violently or ignite spontaneously.

Hydrogen sulfide is extremely toxic. It may cause death instantaneously in high airborne

concentrations. Low levels may be extremely irritating to the lungs, nose, throat and eyes. 

Hydrogen sulfide can be detected by smell at levels as low as 0.13 parts hydrogen sulfide per million

parts air (ppm). Odor cannot be used as a warning because the gas can deaden the sense of smell

within 2 to 15 minutes in exposures of approximately 100 ppm. A single breath of hydrogen sulfide

at about 1000 ppm may paralyze the respiratory system and result in coma and death. Convulsions

may also occur. Prolonged exposure at about 250 ppm hydrogen sulfide may cause the lung tissue

to swell and fill up with water (pulmonary edema). 

This effect may occur after the exposed worker recovers from the irritant effects of the gas.

Exposures of 20 to 50 ppm hydrogen sulfide for one hour may cause inflammation of the cornea and

the delicate lining of the eye and eyelid (a condition called keratoconjunctivitis). Exposures for long

periods at 50 ppm may cause severe irritation of the nose, throat and lungs. Workers exposed to

lower concentrations of hydrogen sulfide may develop headaches, eye disorders and chronic

bronchitis. 

DEECO personal may be exposed to hydrogen en sulfide on a client's premises at levels above the

OSHA permissible exposure limits (20 ppm (ceiling) with the following exception: if no other

measurable exposure occurs during the 8-hour work shift, exposures may exceed 20 ppm, but not

more than 50 ppm (peak), for a single time period up to 10 minutes.). Small amounts of hydrogen

sulfide occur in crude petroleum but natural gas can contain up to 90%. By far the largest industrial

route to H2S occurs in petroleum refineries. Other sources of hydrogen sulfide include coke ovens,

paper mills (using the sulfate method), and tanneries. H2S arises from virtually anywhere where

elemental sulfur comes into contact with organic material, especially at high temperatures.

Should the potential exist for exposure to H2S, the project manager/field team leader will work with

the client to ensure that all personnel are provided with the following training;

1. Identification of the characteristics, sources, and hazards of Hydrogen Sulfide, 

2. Proper use of the Hydrogen Sulfide detection methods used on the site,

3. Recognition of, and proper response to, Hydrogen Sulfide warnings at the workplace,

4. Symptoms of Hydrogen Sulfide exposure,

5. Proper rescue techniques and first-aid procedures to be used in a Hydrogen Sulfide exposure,

6. Proper use and maintenance of personal protective equipment. Demonstrated proficiency in

using PPE should be required,

7. Worker awareness and understanding of workplace practices and maintenance procedures

to protect personnel from exposure to hydrogen sulfide,

8. Wind direction awareness and routes of egress,

9. Confined space and enclosed facility entry procedures.

10. Locations and use of safety equipment,

11. Locations of safe briefing areas,

12. Use and operation of all Hydrogen Sulfide monitoring systems, and

13. Emergency response procedures, corrective action, and shutdown procedures.
DEECO Health and Safety Plan Page 56 January 2010

At most client facilities where hydrogen sulfide exposure could occur, this training is required by

the client prior to entry.

3.12 Lead Awareness

Lead is a toxic metal that was used for many years in products found in and around our homes. Lead

also can be emitted into the air from motor vehicles and industrial sources, and lead can enter

drinking water from plumbing materials. Lead may cause a range of health effects, from behavioral

problems and learning disabilities, to seizures and death. Children six years old and under are most

at risk.

Most Common Sources of Lead Poisoning:

1. Deteriorating lead-based paint,

2. Lead contaminated dust, and

3. Lead contaminated residential soil 

DEECO personal may be exposed to lead hazards created by renovation, repair and painting (RRP)

activities at client facilities that disturb lead-based paint. The lead exposure limit is fifty micrograms

per cubic meter of air (50 ug/m3

) averaged over an 8-hour period. The project manager/field team

leader will ensure that the client has identified any areas where the potential for exposure to lead

exists and access these areas by DEECO employees will be prohibited.
DEECO Health and Safety Plan Page 57 January 2010

4.0 Hazard Communication Requirements

Introduction

The Occupational Safety and Health Administration's (OSHA) Hazard Communication Regulation

(29 CFR 1910.1200) requires that employees be informed of all hazardous chemicals located in their

workplace.

This program will describe how DEECO intends to protect the safety and health of our employees

who are exposed to hazardous chemicals in the workplace, and to comply with the provisions of 29

CFR 1910.1200.

Each supervisor will be held responsible for strict adherence to these policies and will closely

monitor all activities involving hazardous chemicals.

Each employee will carefully follow established work practices and promptly report observed or

potential problems to supervision.

There is no job at DEECO so vital or urgent as to justify the risk of employee overexposure to a

hazardous chemical. Ask when in doubt. Proceed with a job only after being satisfied that it is safe

for you to do so.

A list of all hazardous chemicals for each workplace has been made and is readily available, upon

request, to any employee, working on any shift. It is located in each tow vehicle, shop area, and wet

chemistry lab.

DEECO is responsible to ensure that the list of hazardous chemicals is kept current and that a current

MSDS for each hazardous chemical used is on hand. A chemical that is not shown on the current

list will not be ordered without prior coordination with the wet chemistry lab manager.

All containers of hazardous chemicals in each workplace will be conspicuously labeled with the

identity of the chemical, and the appropriate hazard warnings. If the chemical is a known or

suspected carcinogen, or it is known to affect a specific organ of the body, this information will also

be placed on the container label. The person having supervisory responsibility for the storage or use

or each hazardous chemical will ensure that such labels are not defaced and that they remain legible

at all times. The health and safety officer will ensure that an adequate supply of labels are on hand

and made available to the responsible supervisors.

When an outside contractor is used, it will be the responsibility of the project manager to advise the

contractor of any hazardous chemical to which their employees may be exposed and the appropriate

protective measures to be taken. This procedure also works conversely.

All employees exposed to any hazardous chemicals will complete an information and training

program which includes at least the subjects listed below. New employees must complete similar

instructions before initial exposure to any hazardous chemical in the workplace.
DEECO Health and Safety Plan Page 58 January 2010

Adequate training of all employees exposed to hazardous chemicals will be given by the Health and

Safety Officer or an approved training instructor and assisted as needed by the Hazard

Communication Program Monitor.

Employee information for this program will include:

1. The purpose and need for such a program, including the basic concept that gives every employee

the right to know about hazardous chemicals with which they work.

2. The location and availability of the written Hazard Communication Program, plus the list of

hazardous chemicals and their corresponding MSDS's.

3. The identity upon request, of any chemical to which the employee id exposed. In the case of a

trade secret chemical, the name on the MSDS will be provided.

Employee training shall include at least the following:

1. Methods and observations used to detect the presence or release of a hazardous chemical in the

work ares such as monitoring devices, appearance, or odor.

2. The physical and health hazards associated with each chemical, as specified in the MSDS.

3. Action that employees can take to protect their own safety and health, including specific

procedures that have been established for normal work practices, emergency procedures, and policies

on the use of personal protective equipment.

4. Details of the Hazard Communication Program, including an explanation of the labeling system

used on in-house containers of hazardous chemicals. Also, details of how employees can obtain and

use information contained in the MSDS.

It is the intent of DEECO management to protect the safety and health of each employee, our most

valuable and valued asset. By following correct procedures, no employee should experience and

harmful effects from working with chemicals in their workplace.

Client Responsibilities

Clients are required to inform DEECO personnel working on the premises of all hazards located in

the area. In addition to chemical hazards, the client should inform DEECO:

# Location of all emergency exits.

# Location of nearest medical facilities.

# Location of nearest emergency equipment (fire extinguishers, safety showers,

eyewashes, etc.)

The client should have available for DEECO personnel MSDSs on all chemicals located in the

area(s) where DEECO will be performing work.

The team leader should ensure that the above information is obtained before setting up equipment

to perform the work.
DEECO Health and Safety Plan Page 59 January 2010

DEECO Responsibilities

DEECO is required to inform its employees of all hazards that they may contact. MSDSs for each

chemical used by the Field Division are available in the central MSDS file located at the field office.

DEECO must also supply the client, upon request, information on the chemicals which DEECO

brings on the client's premises to perform field work. MSDSs are present prior to entering the

client's premises.

Written Program

The OSHA regulation requires that DEECO have a written Hazard Communication Program. The

written program for the Field Division is located in Appendix D of this Health and Safety Plan.

4.1 Material Safety Data Sheets

The manufactured or distributor of chemicals used by DEECO is required to supply DEECO with

a MSDS. Employees must be informed of the information on the MSDS prior to working with a

chemical.

A MSDS must exist for all hazardous chemicals. MSDSs for chemicals used on a client's site must

be available for review or photocopying by the client. A list of all chemicals brought on site by

DEECO should be supplied to the client. The client should be informed that a MSDS is available

for each chemical on that list.

Hazardous materials that require a MSDS are substances which may present a physical or health

hazard. A material presents a Physical Hazard if it is:

# Flammable

# Combustible

# Explosive

# Reactive

# Under Pressure

A material presents a Health Hazard if it is:

# Corrosive

# An Irritant

# A Sensitizer

# A Carcinogen

# Harmful to body organs, including skin, eyes, reproductive organs, liver, kidneys,

lungs, blood, or nervous system.

Each MSDS is required to provide the user with the following information:

Section I - Supplier Information. This section must include the manufacturer's name, address, and

an emergency telephone number. Also included in Section I is the name of the chemical as it appears

on the chemical label. Synonyms for the chemical name may also be given.
DEECO Health and Safety Plan Page 60 January 2010

Section II - Hazardous Ingredients Information. This section will list all the hazardous ingredients

of the chemical if they constitute 1% of the mixture or more. If the hazardous ingredient is a

carcinogen (capable of causing cancer), the ingredient will be listed if it constitutes 0.1% of the

mixture or more. Also listed for each ingredient will be the percentage that it makes up of the

mixture, and its current permissible exposure level (PEL).

Section III - Physical/Chemical Characteristics. This section will list characteristics such as boiling

point, vapor pressure, specific gravity, melting point, vapor density, evaporation rate, and solubility

in water. The substance's appearance and odor characteristics will also be given.

Section IV - Fire and Explosion Hazard Data. Included in this section will be the chemical's flash

point, flammability limits (upper and lower), the correct type of material to use to extinguish a fire,

any unusual fire and explosion hazards, and any special fire fighting procedures.

Section V - Reactivity Data. This section will list any conditions that should be avoided with this

chemical, whether or not the chemical is stable, substances the chemical is incompatible with, any

hazardous decomposition products or any hazardous polymerization that may occur.

Section VI - Health Hazard Data. Information included in this section will be possible routes of

exposure, signs and symptoms of overexposure (both acute and chromic exposures), medical

conditions that may be aggravated by exposure to this chemical, and emergency first aid.

Section VII - Precautions for Safe Handling. This section will list steps to be taken in the event of

a spill or release of the chemical, the proper waste disposal methods, and any precautions that should

be taken during handling and storage.

Section VIII - Control Measures. Included in this section will be the proper personal protective

equipment (respiratory protection, gloves, eye/face protection), the required ventilation system, and

other work practices that should be followed when using this chemical.

Section IX - Additional Information. This section will list any other pertinent information such as

transportation requirements or where to get other information regarding the chemical.

4.2 Chemical Labelling

All chemicals used in the field or at DEECO must be labelled. Chemical containers received from

the manufacturer are required to contain the chemical's name, hazard warnings, and the

manufacture's name and address. This manufacturer's label may not be defaced in any manner.

Beakers and other containers used by DEECO employees must also be clearly labelled with the

chemical name at all times.

Several chemical manufacturers place the NFPA (National Fire Protection Association) hazard label

on the bottle. This label identifies some of the hazardous properties of the chemical. 

Transfer containers used by more than one employee must be labelled. Chemical formulas must not

be used (for example, use "Acetone" instead of CH3COCH3

).
DEECO Health and Safety Plan Page 61 January 2010

4.3 Employee Exposure Monitoring

In order to ensure that field personnel are not overexposed to hazardous materials, the DEECO

Safety Officer may direct the Project Manager or Coordinator to perform employee exposure

monitoring.

Results from monitoring surveys will be forwarded to the department managers. The manager must

review the report with each employee in the department. This can be accomplished by reviewing

the report in a department meeting or circulating the report to all employees. Employees must sign

an Employee Notification Form which accompanies the report. The employees' signatures indicate

that the report was reviewed and understood by each employee. The decision to monitor employee

exposure will be made on a project-by-project basis by the DEECO S.O. and the Project Manager

or Coordinator.

The department managers must retain copies of all monitoring reports. These reports should be

reviewed with all new employees, or employees being reassigned to the area, before allowing the

employee to work in the area.

Employees may review past sampling reports that are representative of their exposure by contacting

their department manager, the Director of Personnel, or the DEECO S.O.

4.4 Employee Medical Surveillance

DEECO requires each employee to take a pre-employment physical. This physical establishes the

employee's physical condition before performing work at DEECO. In addition, DEECO field

employees will receive annual physicals based upon their job description and age.

Employees may receive additional medical evaluation if:

# Signs or symptoms associated with exposure to a hazardous chemical at DEECO

develop.

# Routine exposure monitoring indicate that employee exposure exceeds the

Permissible Exposure Level or Action Level for a given substance.

# A spill, leak or other event occurs which may have resulted in exposure to a

hazardous exposure.

These physicals will be provided during normal working hours (when possible) and at no cost to

employees. Copies of all medical evaluations will be forwarded to the Director of Personnel for

placement in the employee's confidential, personal file. Physical evaluations made under the above

conditions shall not reveal findings of diagnoses unrelated to the employee's occupational exposure.

Employees may at any time, review all medical information on file by contacting either the

department manager or the Director of Personnel.

4.5 Employee Access to Records

Employees may be asked to participate in chemical exposure monitoring. DEECO will maintain

records of employee medical surveillance, exposure monitoring, and occupational accidents or

injuries. As per OSHA regulations, this information may be reviewed by employees by requesting
DEECO Health and Safety Plan Page 62 January 2010

the information from the Area Supervisor, Manager or the Personnel Director. A copy of the OSHA

standard regarding access to exposure and medical records may be obtained from the DEECO S.O.

Responsibilities

The DEECO Safety Officer must ensure that:

# All employee exposure monitoring reports are reviewed by employees, and that

employees acknowledge the receipt of the reports by signing the report.

# Copies of the signed report are sent to the Personnel Director.

# Other information, such as MSDSs, ventilation records, etc. are maintained for at

least 30 years.

The Personnel Director must ensure that:

# Employee medical, exposure and accident/injury records are maintained for the

length of employment plus thirty (30) years.

# A response to any internal and external requests for medical or exposure records is

given within 15 working days.

The Department Managers must ensure that:

# Employees review and sign all Employee Exposure reports.

# Employees are advised of the right to access medical and exposure records annually

in a department safety meeting.
DEECO Health and Safety Plan Page 63 January 2010

5.0 Personal Protective Equipment

The procedures and guidelines detailed in the following sections are to be used by DEECO Field

personnel while performing work on either DEECO or client premises. If the client has additional

requirements for personal protective equipment, field personnel are to follow the procedures which

are more stringent. In all cases, all OSHA and/or EPA requirements are to be met. Field personnel

are not to use personal protective equipment for which they have not received adequate training in

their use and limitations.

Protective equipment, including personal protective equipment for eyes, face, head, and extremities,

protective clothing, respiratory devices, and protective shields and barriers, will be provided, used,

and maintained in a sanitary and reliable condition wherever it is necessary by reason of hazards of

processes or environment, chemical hazards, radiological hazards, or mechanical irritants

encountered in a manner capable of causing injury or impairment in the function of any part of the

body through absorption, inhalation or physical contact.

Where employees provide their own protective equipment, DEECO will be responsible to assure its

adequacy, including proper maintenance, and sanitation of such equipment.

All personal protective equipment shall be of safe design and construction for the work to be

performed. The protective equipment, including personal protective equipment (PPE) will be

provided by DEECO at no cost to employees. DEECO will pay for replacement PPE, except when

the employee has lost or intentionally damaged the PPE.

5.1 Respiratory Protection

Detailed information regarding the use of specific respirators is located in the DEECO Field Division

Written Protection Program.

Use

Only employees that have been trained in the use of respiratory protection shall select or wear

respirators. Employees must:

# Be fit-tested and trained annually.

# Ensure that equipment is clean, available, and in good repair.

# Use equipment only as instructed.

# Receive medical clearance to wear a respirator.

# Not have beards, long side-burns, or other conditions that may preclude a good faceto-facepiece seal.

# Ensure that the proper respirator cartridge or canister is used for a particular

contaminant. All cartridges are marked and color-coded.

When donning the respirator:

# Place mask on face with chin in chin-cup.

# Attach lower straps around neck.

# Place top straps on crown of head, above ears.

# Tighten all straps.
DEECO Health and Safety Plan Page 64 January 2010

Each time the respirator is conned, positive and negative pressure fit-checks must be performed.

Positive Pressure Fit-Checks:

# Place the palm of hand over the exhalation valve.

# Exhale gently. The mask should lift off the face without allowing the air to escape.

Negative Pressure Fit-Checks:

# Cover the inlets of the cartridges with hands.

# Inhale gently. The mask should collapse around the face without letting air in around

the face-to- respirator seal.

Selection

Respirators provide specific Protection Factors based on the type to respirator and the cartridge or

canister in use. The Protection Factor is defined as the concentration of an air contaminant outside

the mask divided by the concentration of that some contaminant inside the mask. For example, the

half-mask respirator with HEPA (High Efficiency Particulate Absolute) filter cartridge has a

Protection Factor of 10. This indicates that if worn in an area with a concentration of 0.05 mg/m3

of airborne lead, the employee would actually be exposed to 0.005 mg/m3 of lead.

Employees should select the type of respirator and cartridge based on the decision criteria located

in the DEECO Respiratory Protection written program.

Inspection

Employees must inspect each respirator prior to donning. Straps, inhalation and exhalation valves,

cartridge gaskets, and facepiece should be inspected to ensure all parts are present, clean and in good

condition.

Decontamination

Respirator should be cleaned after each use. Remove cartridges and place them in a plastic bag.

Wash respirator with warm, soapy water. Rinse the respirator thoroughly since soap can be a skin

irritant. Allow respirator to air dry. Place in plastic bag when dry and store in dry location away

from excessive heat. Do not place anything on top of respirator since this may distort the facepiece.

Breathing Air Quality and Use

When DEECO employees are required to use atmosphere-supplying respirators (supplied-air and

SCBA), DEECO will ensure that compressed air, compressed oxygen, liquid air, and liquid oxygen

used for respiration accords with the following specifications:

1. Compressed and liquid oxygen shall meet the United States Pharmacopoeia requirements for

medical or breathing oxygen;

2. Compressed breathing air shall meet at least the requirements for Grade D breathing air

described in ANSI/Compressed Gas Association Commodity Specification for Air, G-7.1-

1989, to include and oxygen content (v/v) of 19.5-23.5%, a hydrocarbon (condensed) content

of 5 milligrams per cubic meter of air or less, a carbon monoxide (CO) content of 10 ppm

or less; a carbon dioxide content of 1,000 ppm or less; and lack of noticeable odor.
DEECO Health and Safety Plan Page 65 January 2010

DEECO will ensure that compressed oxygen is not used in atmosphere-supplying respirators that

have previously used compressed air and ensure that oxygen concentrations greater than 23.5% are

used only in equipment designed for oxygen service or distribution.

DEECO will ensure that cylinders used to supply breathing air to respirators meet the following

requirements:

1. Cylinders are tested and maintained as prescribed in the Shipping Container Specification

Regulations of the Department of Transportation (49 CFR part 173 and part 178);

2. Cylinders of purchased breathing air have a certificate of analysis from the supplier that the

breathing air meets the requirements for Grade D breathing air; and

3. The moisture content in the cylinder does not exceed a dew point of -50 deg.F (-45.6 deg.C)

at 1 atmosphere pressure.

DEECO will ensure that compressors used to supply breathing air to respirators are constructed and

situated so as to:

1. Prevent entry of contaminated air into the air-supply system;

2. Minimize moisture content so that the dew point at 1 atmosphere pressure is 10 degrees F

(5.56 deg.C) below the ambient temperature;

3. Have suitable in-line air-purifying sorbent beds and filters to further ensure breathing air

quality. Sorbent beds and filters shall be maintained and replaced or refurbished periodically

following the manufacturer's instructions;

4. Have a tag containing the most recent change date and the signature of the person authorized

by the employer to perform the change. The tag shall be maintained at the compressor.

For compressors that are not oil-lubricated, the DEECO will ensure that carbon monoxide levels in

the breathing air do not exceed 10 ppm.

For oil-lubricated compressors, the DEECO will use a high-temperature or carbon monoxide alarm,

or both, to monitor carbon monoxide levels. If only high-temperature alarms are used, the air supply

shall be monitored at intervals sufficient to prevent carbon monoxide in the breathing air from

exceeding 10 ppm.

The DEECO will ensure that breathing air couplings are incompatible with outlets for non-respirable

work site air or other gas systems. No asphyxiating substance shall be introduced into breathing air

lines.

DEECO will use breathing gas containers marked in accordance with the NIOSH respirator

certification standard, 42 CFR part 84.
DEECO Health and Safety Plan Page 66 January 2010

5.2 Gloves

Use & Selection

Gloves should be worn when there is a potential for skin contact, such as pouring chemicals,

washing glassware with solvents, collecting samples, etc. Different gloves protect against different

chemicals. The glove compatibility chart below should be consulted when selecting gloves.

Inspection

Employees must check the gloves before donning by:

# Inspecting for cracks, holes, or tears.

# Performing a leak test by grasping the cuff of the glove quickly such that air is

trapped inside the glove. Squeeze the glove to ensure that air cannot escape. If a

glove has any hole, crack, or tear, or has evidence of degradation to the material,

discard the glove.

Employees must ensure that an ample supply of the proper gloves are always available in the field.

Decontamination

Employees should rinse gloves with water before removing. Gloves should be turned inside-out

during removal. Contaminated gloves are to be discarded.

Glove Selection Chart

Chemical(s) Glove Type

Solvents Nitrile (Sol-Vex)

-Chlorinated PVA

Acids, Bases Nitrile (Sol-Vex)

Neoprene (Stanzoil)

PVC Coated

Sample Collection Disposible Latex

5.3 Protective Eyewear

Use & Selection

Chemical and physical hazards in the field have the potential to produce injuries to the eye and face.

These injuries could seriously impair or destroy vision, or permanently destroy facial skin. DEECO

provides eye and face protective equipment to employees at no cost. 

It is the responsibility of the Field Coordinator and Field Employees to ensure that proper eye and

face protection is available and worn in the work area. Contact lenses may not be worn in areas

requiring safety glasses.
DEECO Health and Safety Plan Page 67 January 2010

Eyewear Hazards

Safety Glasses To be worn at all times on the work site or in designated "Eye

Protection Required" areas.

Safety Goggles To be worn whenever there is a potential of a chemical splash

(e.g. handling or pouring solvents.)

Face Shields To be worn when handling or pouring acids, bases, or other

corrosive chemicals; when there is a potential of flying debris

from drilling, cutting or grinding materials with power tools.

Inspection

All safety glasses must meet the American National Standards Institute (ANSI) Standard Z87.1.

Safety glasses are required to have "Z87.1" stamped on the inside of the frame, or etched on the

lenses. DEECO will provide prescription safety glasses to those employees that require corrective

lenses.

Safety glasses, goggles, or face shields that show visible signs of deterioration or damage should be

repaired or discarded. If a damaged item is to be repaired, it should be placed in a plastic bag,

sealed, and labeled "DAMAGED EQUIPMENT: FOR REPAIR".

Decontamination

All safety eyewear should be thoroughly cleaned with soap and water after each use in a

contaminated, or potentially contaminated, area.

5.4 Protective Clothing

In many work situations it may be necessary for field personnel to wear full body protective clothing.

The Project Manager or Coordinator should identify the types of protective clothing that may be

necessary for a particular project, and ensure that the equipment is available at the work site. Brief

descriptions of the various protective clothing materials are given below. In most situations, only

Tyvek or Saranex clothing will be necessary.

Standard Tyvek (non-porous)

Non-woven, olefin fiber fabric. Suitable for protection against most dusts, mists, and fumes.

Fabric melts at temperatures above 270 EF. Should not be used to protect against solvent

vapors or acid gases/fumes.

Saranex Tyvek

Standard Tyvek which has one side coated with saranex plastic. This gives the clothing a

high level of resistance to most hazardous chemicals, including PCBs. Should not be used

in temperatures above 270 EF.
DEECO Health and Safety Plan Page 68 January 2010

Polyethylene Coated Tyvek

Standard Tyvek which has one side coated with polyethylene. This gives the clothing a high

level of resistance to most hazardous chemicals, including PCBs. More resistent to moisture,

and will protect individuals against chemical spills and splashes better than the Saranex

Tyvek. Should not be used in temperatures above 270 EF.

Protective clothing is available in other materials, such as polyvinyl chloride, neoprene, Viton, and

butyl rubber. These materials protect against a higher degree of hazard than Field personnel would

be expected to encounter. If the Project Manager or Coordinator feels that additional protection is

required for a specific project, he/she should discuss clothing options with the S.O.

5.5 OSHA Levels of Protection

Use & Selection

Employees should select the level of personal protective equipment required for each individual

work site based on the current EPA guidelines below. Employees are not to perform tasks in the

work area if the proper personal protective equipment is not available or in good working condition.

At a minimum, employees must wear safety glasses and safety shoes/boots at all work sites. DEECO

employees will not enter areas requiring Level A or Level B protection. All employees will be

trained on the proper use of protection equipment for Level C and Level D protection.

Levels of Protection

Level A - Highest level of respiratory, skin and eye protection is needed. Criteria include:

# High concentration of vapors, gases or particulates.

# High potential for splash, immersion or potential exposure to highly toxic

materials.

# Confined or poorly-ventilated areas.

Equipment:

# Supplied air respirator (pressure-demand SCBA or airline respirator with

escape bottle)

# Fully encapsulating chemical resistent suit

# Inner gloves, chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes coveralls, long cotton underwear, hard hat, disposable gloves and boot

covers, cooling unit, 2-way radios.

Level B - Highest level of respiratory protection, lesser level of skin protection. Criteria include:

# Atmospheres immediately dangerous to life and health (IDLH)

# Oxygen deficient atmosphere (<20%).

# Low potential for splash, immersion or potential exposure to highly toxic

materials.
DEECO Health and Safety Plan Page 69 January 2010

Equipment:

# Supplied air respirator (pressure-demand SCBA or airline respirator with

escape bottle)

# Chemical resistent clothing

# Outer gloves, chemical resistent

# Inner gloves, chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes long cotton underwear, hard hat, disposable gloves and boot covers,

cooling unit, 2-way radios.

Level C - Conditions allow the use of air-purifying respirators. Criteria include:

# Oxygen concentrations not less than 20%.

# Concentrations of identified contaminants will be reduced by the respirator

below the contaminants TLV, and the concentration is within the service limit

of the canister/cartridge.

# Concentrations of contaminants to not exceed IDLH levels.

# Low potential for splash, immersion or potential exposure to highly toxic

materials.

# FID or PID measurements show concentrations only a few ppms above

background.

Equipment:

# Air-purifying, full-face respirator with appropriate canister or cartridges 

# Chemical resistent clothing

# Outer gloves. Chemical resistent

# Chemical resistent safety (steel-toe and shank) boots

Optional Equipment includes long cotton underwear, hard hat, disposable gloves and boot covers,

escape mask, hard hat, 2-way radios.

Level D - No respiratory or skin hazards exist. Criteria include:

# No contaminants present.

# No potential for splash, immersion or potential exposure to any chemicals.

Equipment:

# Coveralls or work clothing

# Safety shoes/boots

# Safety glasses

# Hard hat

Optional Equipment includes gloves, face shield.
DEECO Health and Safety Plan Page 70 January 2010

5.5 Training for the Use Personal Protective Equipment

DEECO will provide training to each employee who is required to use PPE. Each such employee

will be trained to know when PPE is necessary, what PPE is necessary, how to properly don, doff,

adjust, and wear PPE, the limitations of the PPE, and the proper care, maintenance, useful life and

disposal of the PPE.

Each affected employee will be required to demonstrate an understanding of the training and the

ability to use PPE properly, before being allowed to perform work requiring the use of PPE.

When DEECO has reason to believe that any affected employee who has already been trained does

not have the understanding and skill required, DEECO will retrain each such employee.

Circumstances where retraining is required include, but are not limited to, situations where changes

in the workplace render previous training obsolete, changes in the types of PPE to be used render

previous training obsolete, or inadequacies in an affected employee's knowledge or use of assigned

PPE indicate that the employee has not retained the requisite understanding or skill.

DEECO will verify that each affected employee has received and understood the required training

through a written certification that contains the name of each employee trained, the date(s) of

training, and that identifies the subject of the certification.